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FILE NAME DuPont DUP DATE 2018 July 19 DOC DUP302 DOCUMENT DESCRIPTION Legal - Deposition of Raymond A. Anderson - Day 2 Raymond A. Anderson Jr. 7/19/2018 STATE OF MINNESOTA COUNTY OF RAMSEY 163 DISTRICT COURT SECOND DISTRICT PERSONAL INJURY ASBESTOS Court File No 18-169 ROBERT E. BENSON and SUZANNA BENSON Plaintiffs His Wife 3M COMPANY ET AL Defendants VIDEOTAPED DEPOSITION OF RAYMOND A. ANDERSON JR Continued from 7/18/18 Pursuant to Minnesota Rule of Civil Procedure 30.02 a for Sporting Goods Properties and E.I. du Pont de Nemours & Company taken at Law Offices of Murtha Cullina CityPlace I 185 Asylum Street Hartford Connecticut July 19 2018 Doby Professional Reporting Inc. 952-943-1587 1 APPEARANCES 2 Representitnhge Plaintiffs Robert E. Benson and Suzanna Benson 3 KARST & von OISTE 19500 State Highway 4 Houston TX 77070 BY ERIK P. KARST ESQ 5 281 970-9988 epk@karstvonoiste.com 6 7 Representitnhge Defendants E.I. du Pont de Nemours & Company and Sporting Sporting Goods Properties 8 GLYNN & FINLEY 9 One Walnut Creek Center Suite 10 AveCreeknAvenuue 94e596 T. BY ANDREW MORTL ESQ 11 952 945-1974 amortl@glynnfinley.com 12 CROWELL & MORING 13 Washingt,on 20004-259520004-2595 2004-2595 14 : TRATTLES ESQ 202 MARTINEZ 15 gtrattles@crowell.com gtratles@crowel.com gtrat les@crowel .com 16 Following appearances by teleconference 17 Representing Defendant Olin Corporation Representing the 18 HUSCH BLACKWELL 190 Carondelet Plaza Suite 600 19 St. Louis MO 63105 20 480-1835 jackson.otto@huschblackwell.com 21 22 Representitnhge Defendant E.I. du Pont de Nemours -- -- ----.-- . 23 3200 St. Paul StreetSuite 24 BY PETER WANNING ESQ 651 227-9411 25 pwanning@hkmlawgroup.com Raymond A. Anderson Jr. 7/19/2018 164 1 INDEX 2 WITNESS 3 DIRECT CROSS REDIRECT RECROSS Ray Anderson Jr. 169169 216 275 = 295 4 5 EXHIBITS 6 PAGE Defendant's 7 Exhibit 5 1961 Remington Ammunition Price List 218 8 Exhibit 6 1/2/63 Remington Ammunition Dealers Price List Price List .. 231 9 Exhibit 7 1/2/64 Remington Ammunition Price List 233 10 Exhibit 8 information flyer titled New from 11 Remington Plastic Trap and Skeet Loads 238 12 Exhibit 9 USB drive of YouTube video 250 13 Exhibit 10 1967 Remington Sporting Firearms Ammunition Traps and Targets catalog 253 14 release titled Exhibit 11 1/2/68 news Remington 15 Introduces Safety Color Coding for all Gauge Shotshells 67 Exhibit Sporting 257 17 Exhibit 12 1968 Remington Sporting Firearms and Ammunition catalog 260 18 Exhibit Remington Ammunition 28 Exhibit Price1/2/68 Remington Ammunition Components 20 Exhibit 14 1/270 Remington Ammunition Components 265 list 21 Exhibit 15 1972 Remington Sporting Firearms 28 and Ammunition catalog 266 23 Exhibit 16 Plaintiff's second amended notice of deposition of Sporting Goods 24 Properties : 25 12 APPEARANCES Continued Representing the Defendant Union Carbide Corporation 3 ELLIOTT LAW OFFICES 4 Min eaMpoilinsneMian epapoollisis55423 BY PATRICK H. ELLIOT, ESQ 5 612 466-7192 patp@ealtl@ieoltltiloatwt.lnaewt.npat@eleiotltaw.net 6 7 Representing the Defendant Federal Cartridge LITTLETON PARK 8 141 West Front Street Suite 120 Red Bank NJ 07701 9 BY CHRISTINE DELANEY ESQ 732 530-9108 10 christine.delaney@litletonpark.com christine.delaney@littletonpark.com 11 Represnting Industries Representing the Defendants IMO Industries and 12 Warren Pumps MEAGHER & GEER 13 33 South Sixth Street Suite 4400 Minneapolis MN 55402 14 612 371-1321 emugaas@meagher.com 15 16 Representing the Defendant Mine Safety Appliances JARDINE LOGAN & O'BRIEN 17 8519 Eagle Point Boulevard Suite 100 Lake Elmo MN 55042 18 BY PETER F. LINDQUIST ESQ 651 290-6504 287 plindquist@jlolaw.com 287 287 ATTENDANCE Rocco Leone videographer 22 23 24 25 165 1 EXHIBITS Continued PAGE Defendant's 2 Plaintiff's notice Exhibit 17 Plaintiff's second amended notice of 3 deposition of E.I. du Pont de Nemours & Company........ 272 4 18 Goods SExhpibitor, tSpi oSprorttn iingnggGoods ProPprerotpieesrtiesobjoecbtjioensctions notice deposition 5 to notice of ................ 274 19 E.I. de Nemours& Exhibit 6 Exhibit du Pont Company's Company's objections to notice of deposition 274 7 8 Plaintiff's Exhibit Exhibit 20 1/19/71 letter to Dr. J.A. Zapp Jr. 9 from M.W. Kordas Jr. 281 10 retained * Exhibits retained by reporter 12 1561-2 2 2 2 12 1561-2 2 2 2 12 1561-2 2 2 2 12 1561-2 2 2 2 12 1561-2 2 2 2 12 1561-2 2 2 2 12 1561-2 2 2 2 12 1561-2 2 2 2 12 1561-2 2 2 2 1221561-2222222 12 1561-2 2 2 2 1221561-2222222 1221561-2222222 1221561-2222222 1221561-2222222 166 167 Doby Professional Reporting Inc. 952-943-1587 2 Pages 164 to 167 Raymond A. Anderson Jr. 7/19/2018 168 170 1 VIDEOGRAPHER Good morning Today's date 1 about that yesterday My question that I'm going to 2 is July 19 2018. We are going on the record at 2 have for you is at the Bridgeport Connecticut 3 10:05 a.m. This is the videotaped deposition 3 facility for Remington Arms are mold basewads the 4 continuation of Ray Anderson being taken at 4 only containing product that Remington made at 5 Murtha Cullina 185 Asylum Street Hartford 5 that facility 6 Connecticut in the matter of Robert Benson and 6 A. To the best of my knowledge yes 7 Suzanna Benson his wife versus 3M This 7 Q. Therefore if there are sales records in this 8 deposition is being taken on behalf of the 8 case that are produced that show the sale -- I'm sorry 9 Plaintiff filed in the district court second 9 -- the purchase of raw asbestos by Remington Arms at 10 judicial district personal asbestos 10 that particular plant would that be for anything else 11 State of Minnesota County of Ramsey docket 11 besides the mold basewads or is that ? 12 number 18-169 12 MR MORTL Objection to form 13 My name is Rocco Leone cameraman and legal 13 THE WITNESS That's it 14 video technician from VIP Studios Waterbury 14 Q. By Mr. Karst So if those sales records 15 Connecticut with Keli McGilton certified court 15 reflect purchases by Remington Arms of raw asbestos 16 reporter 17 Counsel you may state your appearances for 16 outside of the years in which you've listed on Exhibit 17 1 would you have anything to refute that that would be 18 the record 18 for molded basewad 22228 MR KARST This is Erik Karst for the 19 MR MORTL Objection to form Vague 22228 Plaintiff and we can have the record reflect 22228 everybody who's in the room and on the phone 20 THE WITNESS I don't really understand the 21 question 22228 MR MORTL That's agreeable Thank you 22 Q. By Mr. Karst For example in the bottom of 22228 VIDEOGRAPHER This is the Plaintiff's 23 the sheet Exhibit 1 you have field loads 1961 to 2 second amended notice for du Pont and also for 24 = 1981 correct 25 Sporting Goods Properties Inc. 25 A. Yes 169 1 DIRECT EXAMINATION BY MR KARST 2 3 Q. By Mr. Karst Good morning Mr. Anderson 4 A. Morning Counsel 5 Q. Yesterday we swore you in and you understand 6 that you're still under oath correct 7 A. Correct 8 Q. I'm going to be pretty short this morning and 9 then I think your attorneys have questions for you 10 after I'm finished 11 Between yesterday at the end of deposition and 12 this morning have you reviewed any documents 13 A. No. 14 Q. Have spoken with anybody besides your attorneys 15 A. No. 16 Q. The first question I have for you -- 17 MR MORTL You meant spoken about the 18 deposition I assume 22222 MR KARST Right Not speaking generally 22222 I don't expect that you be mute 22222 MR MORTL Thank you 22222 Q. By Mr. Karst Yesterday you had given me a 22222 _ piece of paper that I'm assuming you have with you a 24 yellow sheet of paper Exhibit 1 that was in your 25 attorney's handwriting and we had spoken at length 171 1 Q. And that's the earliest that you have on this 2 sheet of an containing product being made by 3 Remington Arms correct 4 A. Correct 5 Q. What I'm giving you is a hypothetical If there 6 are sales records or purchase records by Remington of 7 raw asbestos prior to 1961 would those be for mold 8 basewad or anything else 9 MR MORTL Objection to form 10 THE WITNESS I can't answer the question 11 I don't know 12 Q. By Mr. Karst But you're unaware of anything 13 else being made at that plant with raw asbestos ever 14 besides mold basewads 15 A. Correct 16 Q. So not just including the years that you worked 17 there but forever that's the only product that you're 18 aware of 19 A. Yes 20 Q. On the flip side of that if there are purchase 21 _ records of Remington Arms after 1981 of raw asbestos 22 would that be for any other product at the Remington 23 Bridgeport facility besides mold basewads 24 MR MORTL Objection to form 25 Speculation Asked and answered Doby Professional Reporting Inc. 952-943-1587 3 Pages 168 to 171 Raymond A. Anderson Jr. 7/19/2018 172 123 THE WITNESS No. 2 Q. By Mr. Karst Of the loads manufactured 123 with mold basewads between 19 -- you have '61 to 4 '81 If those years are off we can arm wrestle over 5 that but during roughly that time frame what is the 6 most common gauge of shell that is manufactured by 7 Remington for field loads during that time period 8 MR MORTL Objection Overbroad as to 9 tome 10 THE WITNESS gauge 11 Q. By Mr. Karst Would that be the most popular 12 consistently throughout that some window or 13 would vary or that's most popular 14 MR MORTL Same objection Compound 15 THE WITNESS Yes it would be 16 Q. By Mr. Karst The most popular throughout that 17 time period 18 A. Correct 19 Q. What would be the least popular field load gauge 20 during that time frame 21 MR MORTL Objection Overbroad as to 22 time 23 THE WITNESS Least popular fieldload fieldload 2222 Either gauge or 410 25 Q. By Mr. Karst The packaging that shells are 174 1 Q. And what does that generally look like the 2 packaging 3 MR MORTL Same objection 4 THE WITNESS A cardboard box with 5 Remington or Peters on it and a gauge 6 designation and load designation meaning the 7 weight of the load generally the size of shot 8 Q. By Mr. Karst What coloring is on the package 9 MR MORTL Same objection 10 THE WITNESS It varies and it varied over 11 the time period that I worked at Remington too 12 Q. By Mr. Karst Give me how it changed over the 13 years 14 MR MORTL Objection the form 15 Q. By Mr. Karst When you got there in the 60s 16 what was the packaging like coloring 17 MR MORTL Objection Form Overbroad 18 THE WITNESS My memory is little hazy on 19 that but they were green if they were Remington 20 and typically blue if they were Peters 21 Otherwise there was no difference between the 2322 specifications 2322 Q. By Mr. Karst Are these a cardboard box 2322 A. Yes 25 Q. The name itself you said it says on the package 173 123 sold in for field loads does the packaging generally 123 speaking change between the different gauges or is it 123 relatively the same 4 MR MORTL Objection to form Vague 5 Overbroad 6 THE WITNESS When you say for shells are 7 you talking about components or loaded 8 ammunition 9 Q. By Mr. Karst Good question Loaded 10 ammunition Let's tart there 11 A. Okay Now could you repeat the question 12 Q. Sure There's different types of field loads 13 and if you need me to break it down by different gauges 14 I can I'm just trying to make it a little easier 15 A. No. That's okay 16 Q. For field loads is the packaging of a fully 17 loaded field load -- you mentioned once they're fully 18 loaded they put them in a box and that's shipped out 19 A. Correct 20 Q. Is the packaging that in they're in that they're 21 shipped out at is it different from the different 22 gauges or is it relatively the same -- 23 MR MORTL Same objection 24 Q. By Mr. Karst -- during this time frame 25 A. Relatively the same 175 1 Remington or Peters Is the name Remington or Peters 2 color 3 MR MORTL Same objection 4 THE WITNESS I really don't remember I 5 think it was black 6 Q. By Mr. Karst Now you said it changed over 7 the years Let's stick with the early 1980s What 8 would the coloring be at that point for the packaging 9 of the field loads 10 MR MORTL Early 1980s 11 MR KARST Correct 12 MR MORTL Objection to form 13 THE WITNESS Yes I would say relatively 14 the same as what I said for the earlier but the 15 printing might have been different or there 16 might have been a different script Generally 17 you'd have green for Remington and blue for 18 Peters or a lighter color with some scroll work 19 or whatfeorvPeeter rs sometimes 20 Q. By Mr. Karst The name Peters is it printed 21 or written in cursive 22 A. It's printed 23 Q. And how about Remington printed or cursive 24 A. I would call it printed but it's a specific 25 script that it's done in Doby Professional Reporting Inc. 952-943-1587 4 Pages 172 to 175 Raymond A. Anderson Jr. 7/19/2018 176 1 Q. It has that kind of logo how Remington is 2 written 3 A. Yes 4 Q. Has that changed over the years since you worked 5 there or has that stayed relatively the same 6 MR MORTL Objection to form 7 THE WITNESS As far as know it's 8 relatively the same 9 Q. By Mr. Karst So we've just talking about 10 field loads for Remington and so forth Would the 11 packaging ever change if we were talking target loads 12 A. Yes it was different 13 Q. And how was it different target loads And if 14 you could give me the years that would be different the A. can'tabout you started Q. about when you started in the the 606s0s whwhaat t was How 17 the packaging for target loads 18 A. I believe it was similar to the field loads target 19 exceptexcept it said target loads on it dif erence major 222222 Q. Is that the difference in the packagipacnkagging 222222 A. As recall it is yes 2 2 2 Q. How about if we're talking the early 1980s A. Same answer 222222 Q. In regards to the component parts that are sold 25 by Remington yesterday, you gave us a list ofthe 178 1 THE WITNESS I believe some were The 2 prime shells -- no The prime shells were in 3 boxes The power pistons I believe they were 4 sold in plastic bags but not until later on 5 Q. By Mr. Karst As you described them yesterday 6 you mentioned felt wad you also mentioned cardboard 7 wads How were they sold replacements 8 A. Box 9 Q. And how about powder 10 MR MORTL Gunpowder 11 MR KARST Yes 12 WITNESS Powder is sold very carefully 13 in cylinders 14 Q. By Mr. Karst What's the cylinder made out of 15 MR MORTL Objection to form Overbroad 16 THE WITNESS | really don't know 17 Q. By Mr. Karst Is there any type of warning 18 on the powder Objection Objection 19 MR MORTL Objection to form 222222 THE WITNESS | don't recall but I'm sure 222222 there was yes 222222 Q. By Mr. Karst Why do you say you're sure there 222222 were? don't with 222222 A. Because you don't play with gunpowder I would 25 guess there was a child warning or something like that 177 123 component parts Generally are the component parts 123 relatively to same from component to component or are 123 they different 4 MR MORTL Objection Overbroad Form 5 Q. By Mr. Karst For example you mentioned the 6 wads that go within the barrel itself in the shell 7 A. the shell 8 Q. And you've talked about the primer you've 9 talked about the shot you've talked about the powder 10 Is the packaging different from each one of those 11 MR MORTL Objection to form Overbroad 12 THE WITNESS Each one of those components 13 Q. By Mr. Karst Yes 14 A. Yes they're different for each one 15 Q. There's different types of wads power pistons 16 = - yesterday you called them felt you called some 17 cardboard you mentioned the H wad Are those 18 different packaged if we're just talking the wads 19 MR MORTL Objection to form Overbroad 222222 THE WITNESS Different product would be 222222 marked differently but they were all packed in 222222 boxes of a certain quantity 222222 Q. By Mr. Karst Were they ever sold in plastic 222222 bags 222222 MR MORTL Objection to form Overbroad 179 1 on 2 Q. Is there anything that you could show me to show 3 that there actually was a warning 4 A. Me personally 5 Q. Yes 6 A. No. 7 Q. So right now that would be an assumption based 8 on your time there 9 A. Correct 10 Q. And if we're talking the shot itself how a 11 replacement shot packaged 12 MORTL Objection to form 13 THE WITNESS Canvas bags 14 Q. By Mr. Karst How big would the bags be 15 A. I believe they were 20 pounds somewhere in that 16 vicinity 17 Q. And you also mentioned H wads How would those 18 be sold replacements 19 MORTL Objection Overbroad 20 THE WITNESS I don't specifically recall 1 the H wads as far as being a component but I 22 know they were sold and they were sold in 23 cardboard boxes All the components were in 24 cardboard boxes 25 Q. By Mr. Karst Did Remington ever sell - Doby Professional Reporting Inc. 952-943-1587 5 Pages 176 to 179 Raymond A. Anderson Jr. 7/19/2018 180 1 obviously they sold fully loaded shells 2 A. Right 3 Q. Did they ever sell shells that were not fully 4 loaded 5 A. Prime shells 6 Q. Yes 7 A. Yes 8 Q. How would those be packaged 9 MR MORTL Objection to form 10 Q. By Mr. Karst I'm sorry Let me step back 11 Did they sell those for target prime shells 12 A. I don't recall if they specifically sold them 13 for target In fact now let me a backtrack little 14 bit I'm entirely sure that we sold prime shells as a 15 component I think we sold unprimed shells as a 16 component from time to time but not on a regular 17 basis 18 Q. I don't want to put words in your mouth What 19 is an unprimed shell What is there 20 A. No primer Everything else but the primer 2222 Q. The powder and the shot 2222 A. No. sorry It's an empty unprimed shell 23 Q. Okay So if it had a basewad the basewad would 2222 be in there 2222 A. The basewad would be in it 182 1 A. No. 2 Q. Would there be a basewad in the unprimed shells 3 that they would sell 4 A. No I don't believe so 5 Q. So not the plastic nothing 6 A. They might have sold the American shell 7 which is a target shell with a plastic basewad in it 8 but I don't recall ever seeing a molded basewad 9 shell -- 10 Q. Unprimed 11 A. -- for salteo the public 12 Q. Okay I'll first ask you specifically and then 13 I'll go generally If we're talking Minnesota do you 14 have any knowledge as to the type of vendors or 15 customers that Remington would sell their shells to 16 from the plant 17 MR MORTL Objection to form 18 THE WITNESS In the state of Minnesota 19 Q. By Mr. Karst Yes The type of business 20 MR MORTL Same objection 21 THE WITNESS I don't really understand the 22 question 23 Q. By Mr. Karst So if Remington is selling to 24 customers in the state of Minnesota are they selling 25 to individual people Are they selling to gun stores 181 123 Q. And then it would have the metal cap and the 123 plastic body 123 A. Correct 4 Q. So would just have those three components 5 A. That's right 6 Q. Did they sell that for target say during the 7 60s and 70s 8 A. I don't recall 9 Q. Did they sell that for field loads in the 60s 10 and 70s 11 A. I believe so 12 Q. How were those packaged to be sold 13 MR MORTL Objection to form Overbroad 14 THE WITNESS I believe they were in boxes 15 as well 16 Q. By Mr. Karst And would they have a similar 17 description for the loaded shells the boxes or were 18 they different 19 A. They would be different They would say 20 u_nprimed shells 21 Q. But would they still say Remington on them on 2222 the box 23 A. Yes 24 Q. And did they sell these unprimed shells with 25 mold basewads 183 1 Are that selling to department stores And I'm dealing 2 with the decades of the 1960s and 70s 3 MR MORTL Objection to form Broad 4 THE WITNESS I don't know specifically 5 but they would certainly have been selling to 6 customers and gun stores 7 Q. By Mr. Karst And when you say customers 8 you're referring to an individual 9 A. Individual yes 10 Q. So an individual -- 11 A. They were for sale to the public 12 Q. How would an individual go about purchasing 13 directly from Remington 14 MR MORTL Objection to form 15 THE WITNESS They wouldn't Remington 16 didn't sell to the public individually 17 Q. By Mr. Karst When you say customer you're 18 not selling specifically to John Q customer 19 A. No. John Q customer would go to a gun shop or 20 some other outlet 21 Q. the 60s and 70s did department stores to 2222 your knowledge sell Remington products 2222 A. Define department store 24 Q. Dayton's Sears J.C. Penney stores like that 25 A. I really don't know Doby Professional Reporting Inc. 952-943-1587 6 Pages 180 to 183 Raymond A. Anderson Jr. 7/19/2018 184 1 Q. Was there anybody that you're aware of that's 2 alive that might know the answer to that question 3 - A. Probably one of the sales guys I didn't really 4 know too many of the salespeople 5 Q. Did they have sales people for Remington that 6 were broken down by region of the country 7 A. I think so I was never in the sales 8 department so I don't really know the structure but I 9 believe that's true 10 Q. Do you know any names of any gentlemen who ever 11 worked in the sales department 12 A. Kenny Waite 13 Q. W 14 A. Yup 15 Q. Is Mr. Waite still alive 16 A. I don't know He's about my age He's lucky if 17 he 18 Q. Did he live in Connecticut 19 A. Yes he did 222222 Q. Do you have any idea if he had a territory of 222222 sales 222222 MR MORTL Objection 222222 THE WITNESS I don't really know I don't 222222 know how the territories are stored or sales 25 areas are structured 186 1 Q. By Mr. Karst Are those the two minute things 2 customer base 3 A. I would say so but I was never involved with 4 sales or marketing fortunately 5 Q. Is there anybody alive that you're aware of that 6 worked directlfoyr Remington that was involved in 7 marketing 8 A. Kenny Waite I don't know that he's alive but 9 he was involved in marketing and sales 10 Q. What mediums did Remington advertise in that 11 you're aware of Mediums meaning television radio 12 print ads 13 A. Publications 14 MR MORTL Objection to form 15 THE WITNESS Magazines I don't thinkI 16 ever saw a television ad or radio 17 Q. By Mr. Karst Are you aware of - 18 A. Magazines and mailings 19 Q. And who would receive mailings 20 MR MORTL Objection to form 21 THE WITNESS I don't really know 22 Q. By Mr. Karst Again are they customers like a 23 store or is this John Q customer receiving 24 mailings 25 MR MORTL Objection to form Foundation 185 123 Q. By Mr. Karst When was the last time you saw 123 or spoke to Mr. Waite 123 A. Specifically I don't remember but it would have 4 been beforeI retired 5 Q. So before '86 6 A. Yes 7 Q. You did say that Remington sold directly to gun 8 stores 9 A. Yes 10 Q. Would that generally speaking include sporting 11 goods stores 12 A. Yes 13 Q. Or that a separate category for Remington 14 A. Well sporting goods stores that had guns and 15 ammunition for sale 16 Q. Like today Bass Pro Shops has a section like 17 that 18 A. Yes 19 Q. So they would be someone like that 222222 A. Yes I've seen Remington ammunition there 222222 Q. What other types of customers in the 60s and 70s 222222 did Remington have besides the gun stores and sporting 222222 goods stores typically we described a second ago 222222 MR MORTL Objection to form 25 THE WITNESS I don't really know 187 1 Q. By Mr. Karst Or both 2 A. I don't really know I would be guessing 3 Q. You mentioned magazines 4 A. For sure 5 Q. What magazines that Remington advertised in 6 MR MORTL Objection 7 THE WITNESS All the common gun magazines 8 Q. By Mr. Karst And during the 60s and 70s what 9 would those be 10 A. American Riflemen Guns and Ammo I'm drawing a 11 blank but there were probably half a dozen Fairly 12 large circulation magazines back then 13 Q. Let me ask it the opposite way It may be 14 easier Are there any popular gun magazines in the 60s 15 and 70s that Remington did not advertise in that you're 16 aware of 17 MR MORTL Objection 18 THE WITNESS I'm not aware of it 222 Q. By Mr. Karst Would they ever advertise in 222 things like Reader's Digest 222 A. No not to my knowledge 22 Q. So no they didn't or no you don't know 23 A. No they didn't I don't think that would be 24 the kind of publication they would take advertising 2 from That's just an opinion Doby Professional Reporting Inc. 952-943-1587 7 Pages 184 to 187 Raymond A. Anderson Jr. 7/19/2018 188 1 Q. Remington had a publication called Remington 2 Ammunition Components correct 3 A. I believe that was the name of it yes There 4 was an advertising sheet 5 Q. And is that an internal price list of parts or 6 is that something that a gunshot might have 7 A. A gunshot would have a sheet like that It 8 might not have all prices on it There was an internal 9 price list that I remember and an advertising sheet 10 Q. When you say an internal price list that would 11 just be Remington - 12 A. It was for Remington personnel 13 Q. Okay When you worked at Remington at the 14 facility itself did you ever see any du Pont 15 employees 16 A. Yes I did 17 Q. And what would be the purpose ofthe du Pont 18 employees at the Remington plant 19 MR MORTL Objection Overbroad 222222 Q. By Mr. Karst Why were they there 222222 A. There were specific du Pont employees that were 222222 a_ssigned to the Remington location 222222 Q. What was their title 222222 A. Collectively or individually 25 Q. Individually 190 1 MR MORTL Objection to form Foundation 2 THE WITNESS They had specific expertise 3 In this case they were machine designers 4 Q. By Mr. Karst The machines to make what 5 A. Ammunition 6 Q. Any specific components 7 MR MORTL Objection to form Overbroad 8 THE WITNESS I don't really know I know 9 several of the machines that they designed were 10 loading machine and assembly machines 11 Q. By Mr. Karst Are you aware whether du Pont 12 had any separate safety or medical people at the 13 Remington facility 14 MR MORTL Objection to form 15 THE WITNESS I'm not aware I don't know 16 We had medical people but they were employees 17 as far as I know 18 Q. By Mr. Karst How would you know that someone 19 was du Pont employee versus a Remington employee 20 A. If you knew the organization you would know 21 that They worked in a separate group engineering 22 group 23 Q. So the du Pont people worked together amongst 24 themselves 25 A. Yes 189 1 A. I don't remember too many of them Bill Ervine 2 was one 3 Q. Irvine with an ? 4 A. R 5 Q. Anybody else 6 A. He's the one I remember best I worked with him 7 lot 8 Q. Was he actually stationed at the Bridgeport 9 plant 10 A. Yes he was 11 Q. So wasn't visiting He was actually there 12 A. No. These people that I'm talking about now 13 were stationed there 14 Q. But employed by du Pont 15 A. Correct 16 Q. What would be Mr. Ervine's title or titles 17 A. He was senior engineering maybe a senior 18 engineer He was a big power guy 19 Q. Supervisor 222222 A. Lots of experience No. 222222 Q. Hands with the tools guys 222222 A. Yes Designer 222222 Q. If you're aware why would there be du Pont 24 employees at the Remington plant Why are there not 25 just Remington employees at the Remington plant 191 1 Q. But would they also interact with the Remington 2 people at the plant 3 A. Yes 4 Q. Consult on things 5 A. Not so much -- well yes I guess you could say 6 that They would ask about the process and so on and 7 so forth for the machines they were concerned with 8 Q. Would they design machines with Remington 9 people 10 MR MORTL Objection to form 11 THE WITNESS Yes to some degree 12 Q. By Mr. Karst Would they construct machines 13 with Remington people 14 MORTL Objection to form 15 THE WITNESS No. 16 Q. By Mr. Karst Would they supervise processes 17 of manufacture of components of shotgun shells 18 MORTL Objection to form 19 THE WITNESS No. 20 Q. By Mr. Karst When we're talking du Pont 22322 employees at the Remington plant are we walking a 22322 handful or are we talking dozens at a time 22322 MORTL Objection to form 24 THE WITNESS Not dozens If you want to 25 call it a handful that's probably okay Doby Professional Reporting Inc. 952-943-1587 8 Pages 188 to 191 Raymond A. Anderson Jr. 7/19/2018 192 1 Q. By Mr. Karst More than ten 2 A. No. 3 Q. Did the du Pont employee have their own 4 individual area or office that they went to versus the 5 Remington people 6 A. Yes 7 Q. Did they ever wear any type of a hat that would 8 say hey this is a du Pont person or a shirt that said 9 du Pont 10 A. No. 11 Q. Are these suit and tie guys or more blue 12 collars 13 MR MORTL Objection to form 14 Q. By Mr. Karst For their work trades 15 A. They were all professionals They were all 16 _ professionals None of them were blue collar 17 Q. Since you got there in March of '68 were du 18 Pont employees present at the plant at that time to 19 your observations 20 A. Yes 22222 Q. When you left in '86 were du Pont employees 22222 still in and out of the plant at that time 22222 A. No. 22222 Q. If there is a time that you can give me did you 25 longer see du Pont employees at the Remington 194 123 THE WITNESS Two things One would be 123 something with engineering or design and that 123 would be the people that I mentioned before 4 There could be people from Wilmington attending 5 that The other would be safety housekeeping 6 all those things 7 Q. By Mr. Karst What would a du Pont employees 8 be telling Remington employees about safety 9 MR MORTL Objection to form 10 THE WITNESS It was a -- and I don't mean 11 this negatively It was an indoctrination into 12 du Pont's safety habits and standards and so on 13 and so forth They were very very safety 14 conscious 15 Q. By Mr. Karst Were they trying to instill some 16 of their policies of du Pont at Remington that 17 Remington didn't have 18 MR MORTL Objection to form 19 THE WITNESS But the time I got there 20 they had them all 21 Q. By Mr. Karst To your knowledge did du Pont 22 e_mployees ever talk about asbestos or the dangers of 23 _ asbestos since it was being used at the plant at the 24 ~~ Remington plant 25 A. Not to my knowledge no 193 123 Bridgeport facility 123 MR MORTL A regularly assigned station 123 MR KARST Correct 4 THE WITNESS | really don't recall 5 Q. By Mr. Karst Would it have opinion in the 6 last couple years of its existence We're talking the 7 mid 80s 8 A. Yes It was in let's say the last three 9 years 10 Q. Sometime when you were a superintendent of 11 employee relations I'm just trying to time frame it 12 A. Probably Maybe slightly before that 13 Q. Are you aware that when you started at Remington 14 in March of '68 that du Pont had ownership in Remington 15 itself 16 A. Yes 17 Q. Were you aware that the ownership percentage 18 changed during your time period at Remington 19 A. No. 222222 Q. Would Remington hold -- sorry Would du Pont 222222 Ever hold meetings that you would attends at Remington 222222 A. On occasion 222222 Q. And what would be the substance of those 222222 meetings generally speaking 25 MR MORTL Overbroad Form 195 1 Q. You mentioned before that there were asbestos 2 warning signs up and so forth -- 3 A. Yes 4 Q. - the Remington plant 5 A. Correct 6 Q. Did Remington put those up or did du Pont put 7 those up or you don't know 8 MR MORTL Objection Foundation 9 THE WITNESS Remington put them up 10 Q. By Mr. Karst And how do you know that 11 Remington put them up 12 A. I put one up myself 13 Q. Where did you put one up 14 A. Up in the area where the Colton machine was 15 Q. Again refresh our recollection What did the 16 Colton machine make 17 A. The Colton machine made the molded basewads 18 Q. Do you remember what that warning sign said 19 A. Caution I don't remember it whether said 20 asbestos on it or not It may have 2 Q. But it was related to asbestos 22 A. It was related to the Colton production 23 operation which included the use of asbestos 24 Q. But did the sign itself mention asbestos 25 A. That's what I don't recall Everybody Doby Professional Reporting Inc. 952-943-1587 9 Pages 192 to 195 Raymond A. Anderson Jr. 7/19/2018 196 1 understood why it was there but I don't recall 2 specifically if it said asbestos 3 Q. Was it more general as to dust 4 A. No. 5 Q. How big was the sign Since the court reporter 6 can't take that down -- 7 A. 12 by inches I think that was standard for 8 safety signs 9 Q. And where was that hung 10 A. In the Colton area on the wall 11 Q. More than one sign or one 12 A. I believe there were two 13 Q. Two that you hung or two that were there A. Two that I hung in 15 only two in that area Q. Were those the 16 that Were those signs area yes 17 Q.Q. knew to the area or ddid id they old signs 18 replace signs old in signs place signs 19 A. The ones I put up in the old 20 Q. Do you know what the old signs said replacing 22 Q. Same thing you Q. you were iitt whwhyy wouldwould you bebe replacing 23 replacing replacing it with the same thing 25 A. I think one got hit by a forklift truck and I'm not sure about the other one 198 1 the plant suppliers of raw materials that they used to 2 make shotshells 3 MORTL Objection to form Overbroad 4 THE WITNESS Yes 5 Q. By Mr. Karst Do you know any of those 6 individual companies 7 A. Yes I know several of them I'm trying to 8 remember Johns Manville was one of them but that's 9 the one you were looking for right 10 Q. I was going to specifically ask if you didn't 11 mention 12 A. Yes I figured you would 13 Q. Who else 14 A. There were a lot of sales supply people that I 15 really didn't have anything to do with cardboard and 16 advertising and things like that 17 Q. You specifically mentioned Johns Manville SQ 18 I'm obviously going ask you about that Do you know 19 who from Johns Manville had been out there 20 A. No. Q. Was it more than one individual 22 A. I don't know I never attended a meeting with 2 him 24 Q. How would you be aware that Johns Manville had 25 come out to the plant 197 1 Q. But to your recollection they specifically said 2 the same thing or generally they were talking about the 3 same topic 4 A. I'm not sure what that question means 5 Q. So the new sign that you put up did that say 6 word for word what the old sign said 7 A. I believe it did yes It was a replacement 8 Q. Do you remember a gentleman named Ray 9 Beckerdite 10 A. Yes 11 Q. Who is Mr. Beckerdite 12 A. He was the purchasing manager I believe I'm 13 not sure that was his title but that was his function 14 Q. Was he a relatively term employee of 15 Remington 16 A. Shorter than I. 17 Q. Was he there generally speaking when the plant 18 closed 19 A. No. 222222 Q. Was he there when you got there in '68 222222 A. No. 222222 Q. Do you know if Mr. Beckerdite is still alive 222222 A. I don't think he I think I remember reading 222222 an obit 222222 Q. To your knowledge did Remington ever have into 199 1 A. I've read it in correspondence from time to 2 time 3 Q. Internal correspondence -- this is going to be a 4 long question 5 A. Okay 6 Q. Internal correspondence amongst Remington people 7 that this is what's going on at the plant or is this 8 something from Johns Manville saying hey we're coming 9 the plant to discuss some things with you guys 10 A. It would not have been the latter because I was 11 never involved in those kinds of discussions That was 12 purchasing function It probably would have been 13 limited to Ray Beckerdite or one of his subordinates 14 Q. Have you ever heard of a company called William 15 Egleston Company out of Winchester Massachusetts 16 Egleston is G 17 A. I don't recall no 18 Q. They're a supply company out Massachusetts 22222 A. No I don't think I've heard of them 22222 Q. Have you ever heard of Philip Carey 22222 A. Philip Carey 22222 Q. As a company not a person 22222 A. No. 2 Q. Carey A Canadian Mines 2 A. No. Doby Professional Reporting Inc. 952-943-1587 10 Pages 196 to 199 Raymond A. Anderson Jr. 7/19/2018 200 1 Q. How about Raybestos or Raybestos Manhattan 2 A. Sure I lived a mile from them once 3 Q. Do you know if Raybestos ever supplied raw 4 asbestos to the Remington facility in Bridgeport 5 A. I don't know 6 Q. Have you ever heard of Flint Kote 7 A. No. 8 Q. N O 9 A. No. 10 Q. Have you ever heard of Union Carbide 11 A. Yes 12 Q. Are you aware of whether Union Carbide ever 13 supplied raw asbestos to the Bridgeport Remington 14 facility 15 A. I'm not aware of it no 16 Q. Have you ever heard of Certainteed 17 A familiar don't 18 A. Sounds but I recall a specific 19 attachment to my time at Remington 20 Q. Just generally you've heard the name 21 A. Yeah I've heard the name , 22 Q.Q. AreAre you -- aware strsitrkieke thatthathtat 23 There was an & department at Remington in 24 BridgeportBridgeporBridgetport correc?t 25 A.A. Correct . 202 1 Q. After '86 do you know where they went 2 A. No. 3 Q. Would you have any idea if du Pont obtained 4 possession of them or you just don't know 5 A. I just don't know 8 Q. What did the lab notebooks physically look like 7 A. They were black with some lettering on the 8 front and they were probably about 150 pages or so of 9 basically graph paper and dimensionally I would say 10 they were about a foot high and maybe 9 inches wide 11 Q. So close to a standard 8 1/2 by 11 12 A. Yes The pages were probably 8 1/2 by 11 Q. So the binder itself was a little bigger A. Yes 15 Q. Hard cover 16 A. Yes 17 Q. Front and back 18 A. Yes 19 Q. Are these lab notebooks bound or loose paper 222222 They're A. They're bound 222222 Q. Would they have te individual's name on them 222222 A. Yes 222222 Q. On the outside or on the inside ? Inside 222222 A. Inside 222222 Q. And would that be embossed on there or it's 201 203 1 Q. If you're aware the individuals who worked in 2 there did they ever have lab notebooks 3 A. Yes 4 Q. Orjournals that they kept 5 A. Yes 6 Q. Do you know if those still exist today 7 physically 8 A. I don't know firsthand no 9 Q. Are you aware of whether any search has been 10 _conducted by either du Pont or Sporting Goods 11 Properties Inc. to look for or find lab notebooks 12 from the Remington Bridgeport facility 13 MR MORTL Objection Foundation Also 14 I don't know how he would know that except 15 through conversations with attorneys 16 Other than that without waiving anything 17 I'll let you answer if you have any idea how 18 searches were conducted -- 1 somebody's they would just write their name 2 A. They would just write their name 3 Q. Would a lab book foarn individual working in 4 & would they get a new one each year or new ones 5 A. They would get a new one when they filled the 6 old one 7 Q. Fair enough So one could take a month one 8 might take a couple years It just depends on what 9 they're doing 10 A. Yes 11 Q. I know you can't give me an exact number on 12 this so I'm just looking for a general idea The lab 13 notebooks that existed when you left there in '86 are 14 we talking dozens of them or are there literally 15 hundreds of them 16 MR MORTL Objection to form 17 If you know 18 THE WITNESS Yeah I don't know 19 THE WITNESS The lab notebooks were 19 Q. By Mr. Karst Was it a large library 20 cataloged and kept in the & library and from 20 MR MORTL Objection to form 22322 there I don't know where they went 21 THE WITNESS The library was large 22322 Q. By Mr. Karst Let me be clear When you were 22 Q. By Mr. Karst What else would be in the 22322 working there they were kept in the & library 23 library besides lab notebooks 24 A. Yes Or they were kept by the individuals that | 24 22322 kept them and then they went to the & library 25 A. All kinds of books Q. Would they keep lab notebooks from prior years Doby Professional Reporting Inc. 952-943-1587 11 Pages 200 to 203 Raymond A. Anderson Jr. 7/19/2018 204 1 going back 2 A. Yes 3 - Q. Any reason that they would throw out - while 4 you were working there any reason they would throw out 5 lab notebooks 6 A. No. 7 MR MORTL Objection to form Foundation 8 Q. By Mr. Karst Let's move to other things that 9 would be in the library What are some other types of 10 materials that would be in the library 11 A. Reference books encyclopedias a typical small 12 library small as compared to a public library 13 Q. When you say encyclopedia like the Word Book 14 Encyclopedia something like that we're talking 15 A. Yes 16 Q. Would they keep if you're aware literature 17 from vendors to Remington Would they keep source 18 materials from them in the library 19 MR MORTL Objection to form 222222 THE WITNESS Generally no 222222 Q. By Mr. Karst If someone like Johns Manville 222222 would give a pamphlet brochure or a price list or 23 something to Remington where would something like that 222222 be kept 25 MR MORTL Objection to form 206 1 still sitting there 2 A. No. 3 Q. Where would the purchasing records have gone 4 MR MORTL Objection Foundation 5 If you know 6 THE WITNESS I don't know 7 Q. By Mr. Karst Specifically do you know 8 whether they would have gone to du Pont 9 A. I don't know for sure 10 Q. Are you aware when the plant shut down of any 11 records of any type gointgo du Pont 12 A. Not specifically 13 Q. Are you aware of any records specifically going 14 down to -- not any specific records but generally 15 speak are you aware of records that were shipped down 16 to Arkansas the Arkansas Remington plant 17 A. Not firsthand knowledge no but I'm sure the 18 process records are there 19 Q. Would you know whether lab notebooks would have 20 been sent down to Arkansas MR MORTL Objection Foundation 22 THE WITNESS I don't know 22 Q. By Mr. Karst Does Arkansas have an & 23 department 25 A. They didn't when I was there but I was there 205 123 THE WITNESS Probably the purchasing 123 files Definitely not in the library 123 Q. By Mr. Karst Where would purchasing files be 4 kept 5 A. In the purchasing manager's office 6 Q. Ray Beckerdite someone like him 7 A. Yes 8 Q. When you left in '86 did those purchasing files 9 exist to your knowledge 10 MR MORTL Objection to form 11 THE WITNESS I don't recall 12 Q. By Mr. Karst Do you know what has happens to 13 them since then 14 A. Yes 15 Q. What 16 A. What's happened to them 17 Q. Yes 18 A. That building is about thirds of a wreck 19 Q. Meaning it's been torn down 222222 A. Yes No it hasn't been torn down not the 222222 building that purchasing was in but it's just been 222222 totally neglected The windows are all out There's 222222 wholes that people have put in the outside walls with 222222 hammers 25 Q. I guess where I'm going are purchasing records 207 1 very early in their existence soI don't know what 2 they're doing now 3 Q. Just so we're clean when you say you were 4 there you were working for Remington 5 A. I was working for Remington but I was a visitor 6 in Lonoke when I was there 7 Q. So you've been down to that plant 8 A. Yes Several times 9 Q. What would be the purpose of you going down to 10 that plant 11 A. To discuss projects thawte had in common 12 Q. Shotshell 13 A. Mostly centerfire 14 Q. You mentioned earlier that that plant's still in 15 operation today 16 A. Yes 17 Q. Has the physical plant changed over the years 18 since the 70s 19 A. I haven't been there in awhile In fact I 20 probably haven't been there since 70s I don't really 21 know but I've seen a picture of the outside of it and 22 it looks the same to me I think they may have added 23 something onto it 24 Q. Are you aware for this case Mr. Benson's 25 asbestos case are you aware whether any search has Doby Professional Reporting Inc. 952-943-1587 12 Pages 204 to 207 Raymond A. Anderson Jr. 7/19/2018 208 1 been conducted at the Arkansas plant for any records 2 documents lab notebooks purchase records of any type 3 at that facility 4 MR MORTL Objection to form Foundation 5 THE WITNESS I'm not aware 6 Q. By Mr. Karst Are you aware whether anybody at 7 that facility has been contacted to look for records or 8 to look for any documents and so forth related to this 9 asbestos case 10 MR MORTL Same objection 11 THE WITNESS No. 12 Q. By Mr. Karst No it hasn't or no you're not 13 aware 14 THE WITNESS No I'm not aware I lost 15 contact totally with Lonoke whenI retired I 16 haven't been back since 17 Q. By Mr. Karst Do you know if anybody at that 18 facility has been made aware of Mr. Benson's 19 asbestos case and has helped out in trying to 222222 obtain any type of information regarding asbestos 222222 MR MORTL Same objection 222222 THE WITNESS Not aware 222222 Q. By Mr. Karst Do you know who may be aware of 222222 that outside of your attorneys 25 A. Do you mean someone from Lonoke 210 1 A. He was a research engineer 2 Q. And what did he do in Arkansas 3 A. I believe he became a process engineer when he 4 went to Lonoke 5 Q. Are there other individuals who worked in the 6 Bridgeport Remington facility that took a job down at 7 the Lonoke Arkansas facility -- 8 A. Yes 9 Q. -- besides Mr. McMillan 10 A. Yes 11 Q. Would these individuals be engineers and 12 managers versus day machine operators 13 A. Yes generally they would be I don't know of 14 any wage roll people that went down there 15 Q. Working at the Bridgeport facility was there a 16 union 17 A. Yes 18 Q. Were you member of the union 19 A. No. 20 Q. Because you were management is that why you 21 couldn't be 22 A. Yes 23 Q. What union or unions were at the Bridgeport 24 facility 25 A. I don't even remember the name of it It was an 209 123 Q. Yes 123 A. No. 123 Q. If you're aware generally are records at the 4 Arkansas facility 5 MR MORTL Objection Broad Vague 6 THE WITNESS Plant records or corporate 7 records 8 Q. By Mr. Karst Let's go plant records 9 A. Yes I'm sure they are You can't run a plant 10 like that without records 11 Q. Logically How about corporate records 12 A. No not that I'm aware of 13 Q. Are you aware whether they had a library at the 14 Arkansas facility 15 A. I don't recall 16 Q. Do you remember any individuals by name who 17 worked or have worked at the Arkansas facility 18 A. Yes 19 Q. Who are some of them 222222 A. One of them John McMillan deceased good 222222 friend of mine 222222 Q. Was Mr. McMillan from Bridgeport and moved down 222222 there 222222 A. Yes 222222 Q. What did he do in Bridgeport 211 1 house union It was not a national union 2 Q. So it was only for the individuals who worked at 3 this Bridgeport facility 4 A. That's correct 5 Q. When the Arkansas facility opened up did it 6 expand to include that facility 7 A. No. 8 Q. So it was always just the Bridgeport facility 9 A. Yes 10 Q. Do you remember the acronym for ? 11 A. It's coming back to me IMOWU Don't ask me 12 what all that stands for IMOWU we used to call it 13 Q. Was that union in effect when you arrived in 14 '68 15 A. Yes 16 Q. And was that union in effect when you left in 17 '86 18 A. Yes 19 Q. And these were the hourly wage people who were 20 members of this union 2 A. That's right It was not a compulsory 22 membership There were numerous people that were not 23 members 24 Q. What did the union do 25 MR MORTL Objection to form Doby Professional Reporting Inc. 952-943-1587 13 Pages 208 to 211 Raymond A. Anderson Jr. 7/19/2018 212 1 THE WITNESS They represented people in 2 grievance situations They worked together with 3 the company you know with other employees but 4 management type of employees on safety items 5 safety committees It was a good relationship 6 It was not an adversarial relationship 7 Q. By Mr. Karst There were differences of 8 opinion on wages or wage increases as well 9 A. Sure 10 Q. Do you remember whether the IMOWU ever had any 11 grievances or brought up safety concerns regarding dust 12 in the facility 13 A. In my time I do remember and they never did 14 That's an easy one to remember 15 Q. To your recollection during your time did they 16 _ ever bring up asbestos as a concern the union 17 A. Not that I recall no 18 Q. Was there a person that was in charge of the 19 union A president A vice president 222222 A. Yes 222222 Q. Do you remember anyone who served a president or 222222 vice president of that union 222222 A. do 222222 Q. Who 25 A. A good friend of mine Frank Bisignano 214 1 from any related issues or cancer and you told me 2 none that you were aware of 3 A. Correct 4 Q. My follow question to that that I want to ask 5 is are you aware of any individuals who worked at the 6 facility whose spouses or children either were 7 diagnosed with or passed away from any related 8 illnesses or cancer 9 A. No I'm not aware of anything like that 10 Q. Are you aware whether du Pont or Sporting Goods 11 Properties Inc. has been sued in any asbestos 12 __ cases besides Mr. Benson's case that we're here for 13 today and Mr. Taska's case that you testified in a 14 couple years ago 15 A. No. 16 Q. Are those the only two that you're aware of 17 A. Yes 18 Q. Are you aware of anybody for du Pont or Sporting 19 Goods Properties Inc. ever giving a deposition in an 20 asbestos matter as it relates to shotshells and 21 shotguns 22 A. No. 23 Q. You're the only one 24 A. As far as know 25 Q. As far as you know 213 215 123 G I believe it was 123 Q. Was he president or vice president 123 A. President 4 Q. Is Mr. Bisignano still with us today 5 A. No he's not 6 Q. What did Mr. Bisignano do at the facility 7 A. He was a lab technician 1 A. Yes 2 Q. Are you receiving any compensation for your 3 attendance at this deposition 4 A. No. 5 Q. For your time preparing for this deposition 6 either meeting with your attorneys or speaking with 7 them on the phone have you received any compensation 8 Q. & 8 A. No. 9 A. Yes 9 Q. Do you intend that you will receive any 10 Q. So he would be an individual that would have a 10 compensation 11 lab notebook generally speaking 12 A. No. 13 MR MORTL We've going about an hour but 14 I don't want to take a break if you're just 15 about done 16 MR KARST Are you okay for me to keep go 17 for a little bit 11 A. Just for mileage 12 Q. Do you know why you were specifically asked to 13 _ be the representative on the specific topics in this 14 asbestos matter for Remington 15 MORTL Objection I don't know how he 16 could know that without getting into 17 attorney privilege but I'll let him 18 THE WITNESS Define little 19 MR KARST it's going to be more than 20 ten minutes we'll take a break Fair enough 21 THE WITNESS Good 18 answer as long as there's no waiver Is that 19 agreeable 20 MR KARST Sure 223 WITNESS I'm still alive I don't 2222 MR MORTL Thank you 223 mean to be flippant but that's near the truth 2222 Q. By Mr. Karst Yesterday I asked you if you 223 Q. By Mr. Karst Are you aware whether any other 2222 were aware whether any individuals who worked at the | 22 _ individuals besides yourself had ever been contacted to 2222 Bridgeport facility had been diagnosed or passed away 22 __ potentially discuss any asbestos matters as it Doby Professional Reporting Inc. 952-943-1587 14 Pages 212 to 215 Raymond A. Anderson Jr. 7/19/2018 216 1 relates to Remington and the products made at that 2 facility 3 A. Not to my knowledge 4 MR KARST I think that's all the 5 questionsI have for you I know your attorney 6 has some and then I'm sure I'll have follow 7 after that Why don't we take a minute 8 break 9 THE WITNESS Sounds good 11 are going off the record 12 13 * 14 time 15 VIDEOGRAPHER The time is 11:20 We 16 are back on record 18 EXAMINATION BY MR MORTL . : 19 - 222222 Q. By Mr. Mortl Good morning morning Mr.Mr. Anderson are you feeling? 222222 A.A. GoGooodd morning Okay Okay going 23 Q. As you know I'm Andrew Mortl I'm going to How 2 2 2 questions have some for you Let me start by going back to Exhibit 1 the handwritten notes there Can 218 1 Defendant's Exhibit 5 1961 Remington 2 Ammunition Price List marked for 3 identification 4 5 Q. By Mr. Mortl Sir let me show you what's been 6 marked for identification here as Defendant's Exhibit 7 5. Let me ask you generally what is this document 8 A. This is a 1961 Remington ammunition price list 9 Q. And during your time at Remington did you come 11 A. Yes They were generally distributed to 12 employees for information 13 Q. And were these price lists generated on what -- 14 how often 15 A. I believe they were annually unless something 16 you know a special announcement of some kind came out new introduction 18 Q. So these annual price lists continued through Remington 19 your as well 20 A. Yes they did in 2 Q. And were these annual price lists generate in 22 the regular course and scope of Remington's business 2 A. Yes 2 Q. What was the purpose of annual price lists in 2 ThisThis one in parptariticcuulalr ar dedaelasls withwith ammunitamunitiion on correc?t 217 123 you tell me sir why was that created 123 A. It was actually created at my request as a 123 memory aid There's a lot of numbers and dates and 4 stuff of associated with this kind ofthing 5 Q. And why is it that it's not in your handwriting 6 A. I have contracted rather serious arthritis in 7 the last couple years and I'm very uncomfortable 8 writing for more than just a minute or so 9 Q. So how did it get generated 10 A. I asked Gloria to do it for me my attorney to 11 do for me to write it down for me and I dictated it 12 her 13 Q. Without looking at Exhibit 1 it was a memory 14 aid to help you I think you testified remember dates 15 from reviewing various catalogs price lists et 16 cetera correct 17 A. Correct 18 Q. Let's look at some of those actual documents 19 MR KARST Just so we're clear who are 222222 you representing today 222222 MR MORTL I'm representing du Pont SGPI 222222 and the Witness 222222 MR KARST Okay 222222 222222 219 1 A. Correct 2 Q. What's the purpose of annual price lists like 3 this 4 A. For information for -- in the case of employees 5 it was of great interest because they made the product 6 but they're for the sales force and for customers and 7 for distributors It's just general information of 8 what's available from Remington 9 Q. And when you say what's available for Remington 10 _was one of the purposes of the price list to itemize 11 various in this case ammunition that would be 12 available for sale in the upcoming year 1961 here 13 A. That's right 14 Q. And they would update these you said annually 15 there were new products that would come out for 16 example 17 A. Yes 18 MR KARST Objection Overly broad 19 Q. By Mr. Mortl And prices changed 20 A. Yes 21 Q. So from your experience at Remington are you 22 generally familiar with documents like this and 23 comfortable reading documents like this 24 A. Yes am 25 Q. Let me ask you sir tum to the second page of Doby Professional Reporting Inc. 952-943-1587 15 Pages 216 to 219 Raymond A. Anderson Jr. 7/19/2018 220 1 the exhibit which is - before I ask you a question 2 I'm just going to further identify for the record 3 purposes that Exhibit 5 is from SGPI 0002532 to 2547 4 and it's entitled Remington Ammunition Price List 5 effective January 9 1961 6 If you could turn to the second page the 7 document which has a control number at the bottom that 8 ends in 2533. Are you with me 9 A. Yes sir 10 Q. And you see at the top there it says See why 11 Remington new SP shells get you more game Let me ask 12 you do you know what SP refers to 13 A. Yes It's one of the nomenclature from 14 Remington for the new plastic shell 15 Q. When you say new plastic shell based on the 16 documents that you've reviewed is this the first 17 indication that you saw of plastic shell body being 18 introduced by Remington 19 A. Yes 222222 Q. And let me ask you this plastic shell body can 222222 you tell from this document is it being used for both 222222 field loads and target loads orjust field loads at this 222222 this time 24 A. Just field loads at this time 25 Q. Then you'll see at the top hand corner of 221 1 the page there appears to be a section of an 2 actual shotgun shell 3 A. Yes 4 Q. Walk us through if you will just to help 5 orient us it looks like there's bullet points that 6 explain what each thing is I'm going to start at the 7 bottom You see the bottom bullet point points to an 8 exclusive Kleanbore priming 9 A. Yes 10 Q. Is that what you've been referring to as the 11 primer in a shell 12 A. Yes that's right 13 Q. And then you see the next bullet point up has an 14 arrow to the metal base and the description is 15 exclusive steel head Is that what you've been 16 referring to as the head of the shell 17 A. Yes 18 Q. And then the next bullet up points to something 19 that's described as an exclusive basewad and then the 222222 description is hydraulically formed in this shell 222222 around 7 1/2 tons per square inch pressure Does 222222 anything about that description help identify for you 222222 the type of basewad that's contained in this shell 24 A. Yes That's what was known as a molded 25 basewad 222 1 Q. And what's your understanding of the 7 1/2 per 2 square inch pressure 3 A. That was the pressure exerted on the basewad 4 component during its construction or fabrication 5 Q. Is that what you've been referring to in your 6 deposition as the Colton machine 7 A. That's right 8 Q. And so can you give us a description sir of 9 what a molded basewad looked like or felt like 10 after it came out of the Colton machine and had 11 undergone 15,000 pounds per square inch of pressure 12 A. What it looked like and felt like 13 Q. Yes 14 A. Yes I can It was very very hard It was 15 smooth It had a very slight luster to it You could 16 tell that it was made with a punch and a die and a lot voids 17 of pressure because it was very full no no 18 chips no dust no anything like that and it was made 19 in the millions and it was made the same way every 20 time description Q. And And you say very hahrardd Is there there description any there 22 that you can give us of how hard Was it something 23 that you could dent or push on 24 A. No absolutely not not with your hands . There absolutely test your that No I 25 was an initnteerreestsitnging test thathad had seen donedone a couplcouple e 223 1 times when I was at Remington and that was to take the 2 basewads and just throw them on the floor show the 3 employees -- this is part of the training program to 4 show the employee how hard they were 5 Q. They would break when they were thrown on the 6 ground 7 A. They wouldn't break wouldn't chip They were 8 tough 9 Q. And so when the basewads went - after the 10 Colton machine I believe you said they were stored in 11 open bins 12 A. That's correct 13 Q. Is there any dust around those bins 14 A. No. 15 MR KARST Objection to form 16 Q. By Mr. Mortl In all the years that you were 17 there did you ever observe any dust coming off of a 18 molded basewad 19 A. No. 20 MR KARST Objection to form Vague 2 Q. By Mr. Mortl As you would handle these any 22 residue or anything left on your hand 23 A. No. 24 Q. And you said they had a little sheen in them 25 A. Yes Doby Professional Reporting Inc. 952-943-1587 16 Pages 220 to 223 Raymond A. Anderson Jr. 7/19/2018 224 = Q. Was part of the process where they were mixed 2 with wax I think you said paraffin wax 3 A. That's correct I'm sure that's part of the 4 sheen 5 Q. Again if you could give us what your 6 understanding of the ingredients of the molded 7 basewads were 8 A. There was wax wood flour and a small amount of 9 binder which I believe was butyl rubber something 10 ~ along that line And I'm forgetting something 11 Q. Asbestos 12 A. Asbestos yes 13 Q. Fair enough And the butyl rubber that was in 14 to addition the paraffin wax 15 A. Yes It a very small quantity as I recall it 16 Q. That was an additional binder is your 17 understanding 18 A. Correct 19 Q. So going back to this section sir 2 working our way up the next bullet point up says 2 finest progressive buming powder That's what 2 you've been referring to as the gunpowder 2 A. Correct exclusive up 2 Q. Then next up we see exclusive polyethylene H polyethylene discusions discus ions 25 wad We've had a lot of discussions just generally 226 1 well the other use I'm not sure what else might have 2 been in there 3 Q. Let me ask you sir was asbestos ever an 4 ingredient in Remington felt wads 5 A. No. 6 Q. Was asbestos ever an ingredient in the plastic H 7 wads 8 A. No. 9 Q. Was asbestos ever an ingredient in the power 10 piston wads 11 A. No. 12 Q. Was asbestos ever an ingredient in any 13 powder wads 14 A. No. 15 Q. How about in the actual plastic shell 17 construction A. No. in 18 Q. How about in the steel head construction A. in primer 20 How ababoutout in tthhe e primer constructcoinstorucntion 21 Q. How A. 22 Q. SoSo as you've you've alalrreeaaddy y testitefstiifieedd it it was lliimmiitteded 23 to the mold basewads 24 A. Correct plastic 25 Q. How about the plastic basewads 225 123 about wads and some discussion about H wads Is there 123 what you would call an powder wad 123 A. Yes In this case is yes 4 MR KARST Objection to form 5 Q. By Mr. Morti In this particular shell the 6 p _ owdewr ad was an H wad 7 A. That's correct 8 Q. And the next bullet up here says exclusive mold 9 T tite filler was 10 A. Mold 11 Q. Mold filler wad What is that referring 12 to you know 13 A. That's a felt wad 14 Q. And so this particular shell in its original 15 construction had both an H wad and a felt wad 16 A. That's right 17 Q. And again what were the felt wads made from 18 A. They were made from felt material and fibers 19 generally animal fiber horse hair that kind ofthing 20 It's escaping me at the moment but those were the two 21 main ingredients in the fiber wads 23 Q. And it had some kind of binder 23 A. That's right That's what I forgot 22 Q. And what would that generally have been 25 A. It would be -- that might be a butyl rubber as 227 1 A. No. 2 Q. Going on now with this document -- actually let 3 me stay with the felt wad just for one moment sir 4 A. Okay 5 Q. Do you recall when you arrived in 1968 were 6 felt wads being phased out at that time 7 A. Yes 8 Q. And I know it's hard to remember exact dates 9 but to the best of your recollection were felt wads 10 no longer for resale as a component part sometime in 11 the late 1960s 12 MR KARST Objection to form 13 THE WITNESS I believe that's true yes 14 Q. By Mr. Mortl Let me ask it this way What's 15 youryour best recollection of when felt wads were no longer 16 available for purchase as part of a reloading 17 ~~ component 18 A. I would remember better when they went out of 19 use in production and that was very shortly I got 20 there in '68 21 Q. Moving up on this section in Exhibit 5 22 the section of the shell the next bullet point 23 up is the exclusive polyethylene body Do you see 24 that 25 A. Yes Doby Professional Reporting Inc. 952-943-1587 17 Pages 224 to 227 Raymond A. Anderson Jr. 7/19/2018 228 1 Q. And this is the one of the new things right 23 This is the new plastic body 23 A. Correct Yes 4 Q. And then the next bullet point up is the round 5 hard shot and those are for lack of a better term 6 BBs right 7 A. Yeah You could call them that 8 Q. You didn't call them that You called them 9 shot 10 A. We called them shot 11 Q. So for purposes of your deposition when you've 12 been talking about shot that's the section of the ammo 13 that you've been talking about 14 A. That's right 15 Q. And then the last section is the exclusive 16 lokt crimp 17 A. Correct Q. And that lokt crimp that would be the top 19 part of the plastic A. Yes That was part of the body and it was the 20 closure of the this I shell 22 Q. And think you said this is a field load only 23 construction at this time correct 24 A. That's correct 25 Q. Let me ask you , when field loads like this were 230 1 A. Correct That's about a half of an inch maybe 2 eighths of an inch at length on the end of the 3 shell The shot would be gone obviously The felt wad 4 would be gone The H wad be gone 5 Q. Let me phrase the question this way What would 6 be remaining 7 A. Remaining would be the shell body the cap the 8 fired primer and the basewad 9 Q. And in your experience at Remington was the 10 basewad specifically -- let me start with the mold 11 basewad Was it always designed to remain intact in 12 the shell after firing 13 A. Yes 14 Q. And the ejecta I'm assuming that all comes out 15 of the barrel of the shotgun at a fairly high velocity 16 A. Yes 17 Q. And gets shot out to whatever the rifle is 18 aiming 19 A. Correct 222222 Q. The felt wads you know would they 222222 completely degenerate upon firing orjust partially 222222 break up 222222 A. No. They could break up little bit into fibers forth 222222 pieces fibers and so fortforthh and thteyhey would would _ some and have 222222 powder residue that might go around the H wad on their 229 12 - the powder wads might have changed from time to 12 time but the general construction of field wads like 3 this -- let me ask you when a shell like this is 4 fired you mentioned yesterday -- I think you used the 5 term ejecta 6 A. Yes 7 Q. Looking at this section can you explain 8 us what gets ejected from the shell when it was 9 fired 10 A. Yes For this particular shell the shot would 11 be ejected the felt wad would be ejected the basewad 12 would be ejected 13 Q. I'm sorry The basewad or the H wad 14 A. I'm sorry Shame on me The H wad the plastic 15 wad would be ejected The powder would be ejected 16 although almost 99 percent burned form And that is 17 it 18 Q. So after the shell is fired does that mean the 222 remaining components - why don't you tell us what 222 would be the remaining pieces of the shell after you 222 fire that are still intact 22 A. The body would be one of the components and it 23 would be in the same position as you see it in the 24 diagram except that the crimp would be open 2 Q. Where the shot escaped 231 1 surface 2 Q. Did you ever hear of felt wads giving off any 3 little dust or blowback from being fired 4 MR KARST Objection to form 5 THE WITNESS Yes 6 Q. By Mr. Mortl What have you heard or 7 experienced in that regard 8 A. Well you can get small particles of the felt or 9 maybe the horse hair or what have you but it was not a 10 lot of debris the came out of there but there was some 11 evidence that something else was in there besides the H 12 wad which also blew out 13 Q. Same question but this time switching it over 14 With all your experiments or firing of this ammunition 15 while working at Remington ever hear of any blowback 16 issue or dusting issue coming out of the rifle 17 associated with a mold basewad 18 A. No. 222 MR MORTL You can set that document 222 aside Thank you 222 22 Defendant's Exhibit 6 1/2/63 Remington 23 Ammunition Dealers Price List marked for 24 identification 25 Doby Professional Reporting Inc. 952-943-1587 18 Pages 228 to 231 Raymond A. Anderson Jr. 7/19/2018 232 123 Q. By Mr. Mortl Sir for identification I've 123 given you what's been marked as Exhibit 6. It's 123 entitled Remington Ammunition Dealers Price List 4 effective January 2 1963. It bears production numbers 5 SGP10002628 through 2643. Again very similar to the 6 document we just looked at is this one of the annual 7 Remington ammunition dealers price lists 8 A. Yes 9 Q. Again sir is this generally a document that 10 you were familiar that Remington generated annually in 11 the regular course and scope of its business 12 A. Yes 13 Q. And it's a document that you're comfortable 14 reviewing and interpreting 15 A. Yes 16 Q. So we see here the - is it your understanding 17 that this would be the dealer price list for the year 18 = 1963 19 A. Yes 20 Q. Sir if you could please flip to what's marked 21 as page three of the document The control number at 22 the bottom is 2632 23 A. Got it 24 Q. You'll see the top of the document says 25 Remington shur shot plastic shotgun sheets Do you see 234 1 identification 2 3 Q. By Mr. Mort I'm showing you what's been 4 marked as Exhibit 7 which is a Remington ammunition 5 price list effective January 2 1964 with control 6 numbers SGPI 0002700 through 2715. Similar question 7 sir Is this a document that was generated in the 8 regular course and scope of Remington's business 9 A. Yes 10 Q. And there were produced as you understand it 11 on at least an annual basis or thereabouts 12 A. Yes they were 13 Q. And the purpose of these documents as you've 14 already told us was to put out there the various 15 products that were offered for sale in the coming year 16 A. That's correct 17 Q. So we have here the price list from 1964. If 18 you would please -- I would like to direct you to page 19 three of the document It's got control number 2704 at 20 the bottom 21 A. Okay I have it 22 Q. Looking at the top there you see Remington shur 23 shot plastic trap and skeet loads with power piston 24 wad Do you see that 25 A. Yes 233 123 that 123 A. Correct 123 Q. And then you see about halfway down the document 4 it says Remington shur shot target loads 5 A. Yes 6 Q. What kind of shell is associated with the 7 Remington shur shot target load as of 1963 8 A. Paper shell 9 Q. How about below that you see Remington express 10 target load 11 A. Yes 12 Q. What kind of shell is associated those target 13 loads in 1963 14 A. Those were also paper shells 15 Q. Do you see anything in this document that would 16 _ indicate to you that as of 1963 there was anything 17 available for target load other than paper shells 18 A. No. 19 Q. We do see a reference to plastic but that's in 222222 connection with plastic field loads 222222 A. Correct 222222 MR MORTL You can set that one aside 222222 222222 Defendant's Exhibit 7 1/2/64 Remington 222222 Ammunition Price List marked for 235 1 Q. What kind of body construction is that shell 2 A. That is plastic shell 3 Q. Is that for what we've been calling target 4 loads 5 A. Yes 6 Q. And then do you see underneath that there's a 7 reference to a Remington shur shot plastic trap and 8 skeet loads with H wads 9 A. Yes 10 Q. What kind of body shell construction is that 11 A. Also plastic shell 12 Q. And is this 1964 price list the first document 13 you're aware of that indicates that target loads were 14 available for purchase with plastic body construction 15 A. Yes I believe it is 16 MR KARST Objection to form 17 Q. By Mr. Mortl If you look down farther on the 18 same page here the next one down says Remington shur 19 shot paper trap and skeet load with power piston wad 20 A. huh 21 Q. And the one under that Remington shur shot paper 22 trap and skeet loads 23 A. Yes 24 Q. Then the one under that is Remington express 25 paper skeet loads Doby Professional Reporting Inc. 952-943-1587 19 Pages 232 to 235 Raymond A. Anderson Jr. 7/19/2018 236 12 A. Yes 2 Q. What kind of body construction would those three 3 show 4 A. Those were paper 5 Q. So at this point in time Remington was offering 6 both plastic target loads and paper target loads for 7 sale 8 A. That's correct 9 Q. And the mold basewads we've been discussing 10 were those associated with the plastic shells or the 11 paper shells or both or neither as of this time frame 12 Let me ask a better question 13 A. Okay 14 Q. Which target load type of construction paper or 15 plastic contained mold basewad at any point in 16 time 17 A. Which paper 18 Q. sorry I didn't ask you a good question 19 A. No. 2 Q. Let me ask it again 2 A. Go ahead 2 Q. Were mold basewads to your knowledge ever 2 used in paper shells 2 A. No. 25 Q. Were they sometimes used in plastic shells 238 1 A. Yes it is 2 MR MORTL You can set that one aside 3 sir 4 5 Defendant's Exhibit 8 information flyer 6 titled New from Remington Plastic Trap 7 and Skeet Loads marked for identification 8 9 Q. By Mr. Mortl Sir showing you what's been 10 ~~ marked as Defendant's Exhibit 8 in this deposition 11 it's got control numbers SGP10002716 to 2717. The 12 title is New from Remington Plastic Trap and Skeet 13 Loads Can you tell mejust in general what is this 14 type of document 15 A. This is sort of like a press release I think 16 I forget what they specifically call it but it's an 17 information flyer introducing a new product from 18 ~~ Remington 19 Q. And would you see information flyers during the 20 time from Remington that would introduce new products 21 A. Yes 22 Q. And these were the type of documents Remington 23 would generate in the ordinary course and scope of its 24 business 25 A. Yes it was 237 123 A. Yes 123 Q. And were they sometimes used in plastic target 123 load shells 4 A. Yes 5 Q. We see here the two plastic shells They're 6 talking about H wads and power piston wads 7 A. Yes 8 Q. We just saw a picture in the section 9 earlier of an H wad correct 10 A. Yes we did 11 Q. And that's was powder wad 12 A. Correct 13 Q. And that's ejected when the shell is discharged 14 A. That's right 15 Q. Similarly is the power piston wad an 16 powder wad 17 A. In some loads it is 18 Q. And it's ejected when it's fired 19 A. Yes 222222 Q. When you say the power piston is an powder 222222 wad in some shells do you mean it's not in every 222222 shell 222222 A. No it's not correct 222222 Q. But the shells it is in it's an powder 222222 wad 239 1 Q. Wejust saw from Exhibit 7 which was the 1964 2 price a reference to a Remington shur shot 3 plastic trap with a power piston and then we see this 4 flyer that is introducing the new power piston 5 correct 6 A. Yes 7 Q. And the new plastic bodies correct 8 A. Yes 9 Q. Let's take look at this one in little more 10 detail Again in the upper hand corner we have a 11 section of a shotgun shell is that correct 12 A. Yes 13 Q. And this one is not -- unlike the last one we 14 looked at that had little bullet point on each one for 15 description this one doesn't so I'm going to ask you 16 to walk us kind of through the shell slowly here I'm 17 going to walk you up it and what I'm actually going to 18 do give you a red pen too if you want to mark as 19 we go Starting at the bottom of the shell in the 20 ~~ middle of the bottom there's little cylinder Could 21 you identify in your exhibit just with a little arrow 22 -- know you can't -- I'm not going to ask you to 23 write lot with your arthritis but could you maybe just 24 put P and verify for me that that is the primer 222 A. The primer correct Doby Professional Reporting Inc. 952-943-1587 20 Pages 236 to 239 Raymond A. Anderson Jr. 7/19/2018 240 123 Q. And then as we go to the left or the right of 123 the primer do you see something that you would 123 associate with a basewad 4 A. Yes 5 Q. What kind of basewad 6 A. That's a molded basewad that's encapsulated 7 in polyethylene plastic 8 Q. Okay Let's go one step at a time If you 9 could identify the molded basewad if it's not too 10 much trouble with just a DW 11 A. Okay 12 Q. Just so we're got a clear record what did you 13 write 14 A. DMBW is what I'm trying to write 15 Q. Perfect molded basewad Then we see above 16 the molded basewad a white line Can you tell us 17 what that is 18 A. That's the encapsulating plastic that surrounds 19 the basewad This is the thicker portion of it between 20 the molded material and the material 22222 Q. So during the construction there's an extra 22222 _ plastic liner above the molded basewad 22222 A. Yes Above and all around 22222 Q. So you identified that with - 22222 A. PE polyethylene 242 1 A. POW 2 Q. Whatever your hand will allow I should 3 probably be writing this for you I apologize but 4 it's hard for me to reach across the table 5 A. That's all right There's only a few more 6 Q. Then what's the next component as we move up the 7 shell 8 A. The next component is the power piston and the 9 area of it there that shows the through holes used to 10 be known as the skirt of it 11 Q. But it part of the power piston 12 A. It's part of the power piston It's an integral 13 unit 14 Q. Could you put an arrow with a PP 15 A. Sure 16 Q. And so is it in this shell this target load - 17 this is a target load shell right 18 A. Yes it is 19 Q. And this target load shell it contains a power 20 piston powder wad 21 A. Correct 22 Q. Not an H wad 23 A. That's correct 24 Q. And not a felt wad 25 A. That's correct 241 123 Q. Polyethylene Okay Similarly if you look at 123 the text of the document down in the bottom hand 123 corner the last bullet point you'll see the section 4 that starts easy reloading and if you go to the second 5 sentence it reads basewad enclosed in plastic ensuring 6 uniform height gives positive gas sealing prevents 7 deterioration after repeated use of cases Do you see 8 that 9 A. Yes 10 Q. Is that what you've just labelled as PE the 11 basewad enclosed in plastic Is that what you're 12 referring to 13 A. Yes 14 MR KARST Could you show me exactly what 15 he's pointing to in that regard 16 MORTL Sure See the plastic 17 MR KARST The H wad 18 MR MORTL No. No wad We'll keep 19 walking through This one's got a power piston 20 in 222222 Q. By Mr. Mortl Going back to the section 222222 above the polyethylene plastic enclosure of the 222222 basewad what's the next component 222222 A. The powder 25 Q. Can you put maybe a P 243 1 Q. Did power pistons become the more standard wad 2 for target loads after they were introduced 3 A. Yes 4 MR KARST Objection to form Vague 5 Q. By Mr. Mortl What your understanding of why 6 they became the more standard powder wad used in 7 target loads 8 MR KARST Objection to the form 9 THE WITNESS There's a number of reasons 10 The most important ones are that one of the 11 major features of the power piston was that it 12 protected the shot as it went down to the bore 13 of the shotgun and in large part kept it from 14 deforming If you fire a power piston type 15 or shot container type load you can see 16 from high speed photography that the shots are 17 deformed in exactly the way you might suspect 18 They look like they're wiped on one side and 19 the lead is substantially deformed 20 Q. By Mr. Mort Actually flip over to the other 21 side of the document sir I want to show you 22 something 23 A. Yes 24 Q. Is that the high speed photography that you're 25 referring to Doby Professional Reporting Inc. 952-943-1587 21 Pages 240 to 243 Raymond A. Anderson Jr. 7/19/2018 244 12 A. is yes 12 Q. So part of the power piston is it has plastic 3 that comes up on either side of the shot 4 A. Correct 5 Q. So it helps hold the shot in place 6 A. Correct They call that the shot container 7 Q. And so for target shooting was it Remington's 8 belief that the power piston also gave you more 9 accuracy 10 A. Yes absolutely 11 Q. Is that because the shot would stay in a more 12 confined area 13 A. Correct 14 Q. And that's what these pictures purport to show 15 A. Yes 16 Q. And you'll see the second picture down This is 17 the second photograph down on page 2717. It says This 18 is the shot string at 33 inches The power piston has 19 finished its job and separated from the shot There's 20 no dust or debris to blow back into your face In 21 fact when you're shooting you never even see the 22 power piston It will never upset your point or your 23 concentration Do you see that 24 A. Yes 25 Q. We talked about blowback a moment ago Was it 246 1 Q. Then the next one the BBS as I call them is 2 that the shot 3 A. The shot yes 4 Q. If you'll go ahead and put an S by that And 5 then the other two parts I think we haven't discussed 6 would you identify at the bottom the metal pieces at 7 the head 8 A. Yes The cap surrounds the lower end of the 9 shell 10 Q. And do you refer to it as cap or head or either 11 or 12 A. Cap or head either or 13 Q. I think we've been calling them a head through 14 most of the deposition so I'm going to stick with 15 that if that's not too confusing 16 A. That's fine 17 Q. can you go ahead and mark that 18 A. Okay This pen doesn't want to write on this 19 paper 20 Q. I promise not to make you write too much more 21 The last one can you identify -- the green part of the 22 o_uter body here is that the green plastic body of the 23 shell 24 A. Yes is 25 Q. Again is that the plastic crimp at the top as 245 1 your understanding that one ofthe benefits of the 2 power piston over something like a felt wad was that it 3 eliminated debris dust and blowback 4 A. Yes 5 Q. You had mentioned it also eliminated contact 6 with the metal of barrel 7 A. Correct 8 Q. The shot with the metal barrel 9 A. That's right 10 Q. If you look at the hand column of page 2717 the exclusive power piston and you go down to 12 the second sentence you'll see that one ofthe stated 13 benefits here is that first by completely eliminating 14 contact with the metal of the barrel Is that what 15 you're referring to 16 A. Yes 17 Q. If you look down at the bottom hand do you 18 see -- as of the time ofthis document you'll see the 19 various specifications of different shells Were there 20 still some paper target loads available for sale 22222 A. Yes there were 22222 Q. Flipping back over please to the first page 22222 let's finish this section and the different 22222 ~ 22222 c_omponents here We just discussed the power piston A. Correct 247 1 well 2 A. Correct 3 Q. And the crimp is actually part of the actual 4 shell body correct 5 A. That's right It's folded in on itself 6 Q. Again looking at this particular section 7 when this type of target load is fired can you tell us 8 what gets ejected from the shell and what stays in 9 place 10 A. Sure The crimp opens up remains part of the 11 shell the shot is ejected the power piston is 12 ejected the powder is burned and whatever's left of 13 it is ejected which is very little And that is all 14 that's ejected 15 Q. Okay Does the mold basewad staiyn the 16 shell 17 A. Yes it does 18 Q. Does the plastic that's enclosing it stay in the 19 shell 20 A. Yes it does 223 Q. Does the spent primer stay in the shell 223 A. Yes it does 223 Q. You'll see a description of the plastic 24 enclosing the basewad It says one of the benefits of 22 is it prevents deterioration after repeated use of Doby Professional Reporting Inc. 952-943-1587 22 Pages 244 to 247 Raymond A. Anderson Jr. 7/19/2018 248 1 cases Were these shells designed to be reloaded if 2 someone chose to do that 3 A. Yes they were 4 Q. In your experience in both your own personal 5 reloading and the work that you did at Remington what 6 would be the first thing to fail on target loads that 7 were repeatedly fired and reloaded 8 MR KARST Objection Overly broad 9 THE WITNESS The crimp of the shell 10 because on repeated reload -- each time you 11 reload you have to refold it and you 12 eventually cause stress rises in the plastic 13 and it splits 14 Q. By Mr. Mort So if a shooter testified that 15 they repeatedly reloaded shells and that the only thing 16 they recall failing on a Remington shell that they had 17 reloaded was the crimp that would be consistent with 18 your experience as well 19 A. Yes 222222 Q. And if Mr. Benson testified to that that would 222222 be consistent with your experience 222222 A. Yes 222222 Q. If for any reason the molded basewad was 222222 removed - and I know it wasn't designed to be removed 25 but if for some reason it was removed from a shell 250 1 discussed whether they be the felt wads the H wads or 2 the power piston wads those at various points in time 3 were sold by Remington as reload component parts 4 correct 5 A. Yes's that right 6 Q. And the powder wads are those the wads 7 that get replaced in the reloading process of target 8 loads 9 A. Yes 10 Q. While we're talking about target load shell 11 reloading you testified that's something that you've 12 done yourself correct 13 A. Yes that's right 14 Q. And you've see MEC loaders before 15 A. Yes 16 17 Defendant's Exhibit 9 USB drive of 18 YouTube video marked for identification 19 20 MR MORTL I'm going to mark as Exhibit 9 a copy of little instructional video that I'm 2 going to show you 23 Counsel I don't know if you want to go 2 around so you can see as well I'm going to 2 show him this video and ask him generally if it 249 123 could it be reloaded and reused 123 A. No. 123 MR KARST Objection to form Overly 4 broad 5 Q. By Mr. Mortl Why not 6 A. First of all it would destroy the structural 7 integrity of the shell and secondly there would be a 8 vast amount of volume empty in the shell 9 Q. And you've already testified I believe 10 ~~ Remington never sold molded basewads on the open 11 market for part of a reloading process is that 12 correct 13 A. That's correct 14 Q. Because they weren't designed to be part of a 15 reloading process 16 A. That's correct 17 Q. They were designed to stay intact in place 18 A. Correct 19 Q. Until the crimp failed 222322 A. That's right 222322 Q. As designed is the mold basewad to be 222322 disturbed in any way as part of a reloading process 222322 A. No. 222322 MR KARST Objection to form Vague 25 Q. By Mr. Mortl The powdewar ds that we've 251 1 accurately depicts the reloading process 2 For folks on the phone if you've got your 3 computers in front of you you can go to YouTube 4 and type in basic how to reload a shotshell 5 with a MEC reloader and this video should come 6 up It's 3 minutes 19 second by Gunsmith USA 7 That is the title of it It's got a YouTube 8 search line of TAENNPGNL dash 8 but I think 9 it's probably better to search for it by name 10 MR KARST Obviously I'll object to the 11 video I don't know who produced it don't know 12 what year it's from don't know the machine 13 don't know any foundation basis whatsoever about 14 people in the video anything so totally 15 objection to this one 16 MR MORTL Your objection is noted Let's 17 play the video and go from there 18 If you could watch what's been marked as 19 Exhibit 9 please 82282 82282 Video playing 82282 82282 Q. By Mr. Mortl Sir having watched the video 82282 marked as Exhibit 9 can you tell me is that 25 consistent with your understanding of the basic Doby Professional Reporting Inc. 952-943-1587 23 Pages 248 to 251 Raymond A. Anderson Jr. 7/19/2018 252 1 reloading process 2 A. Yes 3 - Q. And that basic MEC reloading process although 4 it might have gotten more automated over time has it 5 changed in the course of your career 6 A. No. 7 Q. So it's the same kind of stages 8 A. Steps Correct 9 Q. So from what we just saw does any part of that 10 _ process disturb whatever type of basewad is in the 11 shell 12 A. No. 13 MR KARST Objection to form 14 Q. By Mr. Mort And for mold basewads in 15 particular were they designed to stay intact and in 16 _ place during the reload process 17 A. Yes 18 Q. And would you describe a molded basewad as a 19 component part of a shell or an integrated part of a 222222 shell 222222 A. It's integrated part 222222 Q. And what do you mean by that 222222 A. Well once the shell is assembled there's no 222222 reason or intent that the basewad be removed so it 25 stays there for the life of the shell 254 1 Q. Again just generally what is this document 2 A. This is a catalog showing Remington's offerings 3 for the year 1967 for firearms and ammunition traps 4 and target 5 Q. And were documents like this generated in the 6 regular course and scope of Remington's business 7 A. Yes 8 Q. On an annual basis or thereabouts 9 A. Correct 10 Q. And similar to the price list we looked at are 11 you comfortable reviewing Remington catalogs 12 A. Yes 13 Q. You're familiar with them 14 A. Yes 15 Q. Let me go ahead since we're on this one and 16 take you quickly to the page It's page 40. It's got 17 control number 2969 on it 18 A. Got it 19 Q. So this is a page entitled Remington Traps and 20 Skeet Loads Do you see that 21 A. Yes 22 Q. I just wanted to get you to the target load 23 section here We see the section of the target 24 load shell there on the left side 25 A. Yes 253 1 Defendant's Exhibit 10 1967 Remington 2 Sporting Firearms Ammunition Traps and 3 Targets catalog marked for identification 4 5 MR MORTL We've got about two minutes 6 left on the tape and we've been going for a 7 while so let's take a quick break and let you 8 stretch your legs 9 VIDEOGRAPHER The time is 12:15 p.m. We 10 are going off the record 11 12 ***** 13 14 VIDEOGRAPHER This time is 12:25 p.m. This 15 is the beginning of tape two We are back on 16 record 17 Q. By Mr. Mortl Sir I'm showing you what's been 18 marked as Exhibit 10. Could I have that red pen back 19 from you please 20 A. Certainly 21 Q. Exhibit 10 for the record identifying is the 22 Remington 1967 Sporting Firearms Ammunition Traps and 23 Targets It's got control numbers SGP10002930 through 24 = 2973. Do you recognize this document sir 25 A. Yes do 255 1 Q. Similatro the section that we just looked 2 at and walked through in detail similar composition 3 here 4 A. Do you want to start at the bottom or the top 5 Q. You can just look at it and tell me if it's 6 similar composition 7 A. Yes it's similar composition 8 Q. And similar to what we just looked at the 9 molded basewad can you tell me from this diagram 10 is still enclosed in the plastic 11 A. Yes it is 12 Q. Okay Go down to the bottom of this particular 13 page sir and you're going to see something that 14 refers to gauge International target loads 15 A. Yes 16 Q. We talked about -- you were asked some questions 17 yesterday with respect to Exhibit 4 about International 18 target loads Let me ask you a little bit more about 19 that Were there different specifications for 20 International target load than there were for other 21 target loads 23 A. Yes there be 23 Q. And how so 24 A. The biggest differences that I recall were that 25 it was a plated head on the shell it had Doby Professional Reporting Inc. 952-943-1587 24 Pages 252 to 255 Raymond A. Anderson Jr. 7/19/2018 256 1 plated shot and it was a substantial cost 2 increase price increase for the customer 3 Q. And how about for sanction shooting competitions 4 the United States for United sanctioned 5 shooting competitions were International target loads 6 allowed to be used 7 A No. 8 Q. So for this Intemational specification you 9 said they were more expensive How about volume 10 how did they compare with Remington's other target load 11 production and sales 12 A. Very low volume I thought about this alittle 13 bit last night when I was going through some stuff and 14 I can recall quite clearly that we ran these on one 15 loading machine for one shift in one year that I was 16 there remember that specifically 17 Q. Very low volume 18 A. Very low volume 19 Q. Do you think these were even available for purchase 22222 most places in the US 22222 22222 Q. And just as a refresher the document that we 22222 looked at yesterday , Exhibit 4 which was a 1968 list , International 22222 the International target loads were the only target 2 load shells that still were listed on that particular 258 1 A. Yes it was 2 MR KARST Objection to form 3 Q. By Mr. Mortl And these news releases were 4 generated in the normal course and scope of Remington's 5 business 6 A. Yes 7 Q. This one January 2 1968 if you look at the 8 first paragraph the document says Remington Arms 9 Company Inc. has announced that all Remington 10 gauge shotgun shells will now have yellow color 11 coded bodies to ensure positive visual contact between 12 12- and gauge shells Do you see that 13 A. Yes point Q. 14 Yesterday you testified that at some point in 15 time gauge shotgun shells went to all yellow Do that 16 you recall 17 A. That's right consist 18 Q. Is this document consist with your recollection 20 regard A. . 21 Q. Go to the second page of the document under the 23 American target New gauge target loads now available from Remington Do you see that 24 A. Yes 25 Q. Q. YeYsteesrtdearyday you hahadd tteesstiiffiieded thatthat atat some poinpotint 257 1 document that contained the mold basewad correct 2 A. That's correct 3 MR KARST Objection to form Misstates 4 the document 5 6 Defendant's Exhibit 11 1/2/68 news 7 release titled Remington 8 Introduces Safety Color Coding for all 9 Gauge Shotshells marked for 10 identification 11 12 Q. By Mr. Mortl Sir showing you what's been 13 marked as Exhibit 11 which is a Remington news 14 release dated January 2 1968 entitled 15 Remington Introduces Safety Color Coding for all 16 = Gauge Shotshells It's got control number 17 ~~ SGPI0003050 through 3053. Again we saw some news 18 releases or press releases earlier Is this of a 19 similar vein Let me ask you a fresher question 20 ~~ Would Remington put out news releases or press releases 22222 from time to time when it would change products 22222 A. Yes 22222 Q. And that happened during the time -- that was a 22222 regular occurrence during the time you worked there as 22222 well 259 1 time Remington introduced an American target 2 load shell Do you recall that 3 A. Yes 4 Q. Does this document help refresh your 5 recollection on the timing for the introduction of that 6 shell 7 A. Yes 8 Q. So it would have been sometime around when 9 A. looks like January 2 1968 10 Q. And if you go down the third paragraph on this 11 page do you see a key feature of the new shells is a 12 locked piece solid plastic basewad whose design 13 aids in a faster more completely uniform ignition and 14 whose strength increases even further the inherent 15 reloadability of the strong plastic shell bodies Do 16 you see that 17 A. Yes 18 Q. Is that consistent with your memory that the 19 American shell contained a solid plastic basewad 20 A. Yes 2 Q. And not a mold basewad 22 A. Correct 23 Q. And at the very bottom of the page you'll see 24 they said they will be available January 1968. Do you 25 _ see that the very last sentence Doby Professional Reporting Inc. 952-943-1587 25 Pages 256 to 259 Raymond A. Anderson Jr. 7/19/2018 260 12 A. Yes 12 MR MORTL You can set that aside sir 3 Thank you 4 5 Defendant's Exhibit 12 1968 Remington 6 Sporting Firearms and Ammunition catalog 7 marked for identification 8 9 Q. By Mr. Mortl I'm showing you what's been 10 marked as Exhibit 12. This is Remington 1968 11 Sporting Firearms and Ammunition SGP10003010 through 12 3049. Sir can you tell us what this document is 13 A. The 1968 Sporting Firearms and Ammunition 14 catalog for Remington 15 Q. So this is again one of the annual catalogs 16 that Remington would put out 17 A. Yes 18 Q. And you're familiar with these documents 19 A. Yes 222222 Q. And this document was generated in the regular 222222 course and scope of Remington's business 222222 A. Yes 222222 Q. And similatro the price lists we were looking 222222 at it's one of the purposes of these catalogs to 25 _ inform potential customers of the various product lines 262 1 A. It's a plastic basewad 2 Q. And all the other components are similar to what 3 we've seen in other sections as far as primer 4 head powder powder wad shot and plastic body 5 construction 6 A. Yes 7 Q. And you'll see under the American 8 description it says The secret is in the new 9 piece plastic basewad Again is that consistent 10 with your recollection that there was no mold 11 basewad in the Americans 12 A. Yes 13 Q. And that Remington had moved towards a plastic 14 basewad 15 A. Yup 16 MR KARST Objection to form 17 MR MORTL You can put that one aside 18 sir 19 20 Defendant's Exhibit 13 1/2/68 Remington 21 Ammunition Components Price List marked 2 for identification 23 2 Q. By Mr. Mortl I'm showing you what has been 25 marked as Exhibit 13 which is a Remington Ammunition 261 1 contained in the catalogs 2 A. Yes 3 Q. If you could turn to page 24 of the document 4 it's got the control number 3033 at bottom It's page 5 24 of the actual document 6 A. have it 7 Q. So we're on the same page here it's titled 8 Remington Trap and Skeet Loads 9 A. Yes 10 Q. Again about halfway down in this 1968 catalog 11 we see all new American 12 A. Yes 13 Q. Do you see that 14 A. huh 15 Q. Is that consistent with your memory of when you 16 started 1968 that the American had become trap 17 load 18 A. Yes 19 Q. And you'll see another section of a shell 20 A. Yes 21 Q. On the upper hand part of the document 2222 Can you tell from the photo are we now where -- is 2222 there a mold basewad in that section 2222 A. No there's not 2222 Q. What kind of basewad is in this 263 1 Components Price List effective January 2 1968. At 2 totpop it says 1968 Suggested Retail Price List It's 3 got control number SGP10002986 through 2993. Tell me 4 what this document sir 5 A. This is a catalog listing of all the component 6 parts of various types of shells that Remington had for 7 sale in 1968 8 Q. And for the ammunition components price list 9 similar to the other price lists we looked at this is 10 an annual publication by Remington 11 A. That's correct 12 Q. And it's put out in the regular course and scope 13 of Remington's business 14 A. That's right 15 Q. And it's a document that you're familiar with 16 A. Yes 17 Q. So this is ammunition components price list So 18 these would be -- is it accurate to say that these 19 would be include the types of things that we've talked 20 a_bout that get replaced as part the target reloading 21 process 22 A. That's right 23 Q. you flip to page five please control number 24 29902990 at the bottom 25 A. have it Doby Professional Reporting Inc. 952-943-1587 26 Pages 260 to 263 Raymond A. Anderson Jr. 7/19/2018 264 1 Q. And you see the title of this page is Wads and 2 it says Remington wads are offered in the famous 3 polyethylene plastic power piston 4 A. Yes 5 Q. Post wad and H wads 6 A. Yes 7 Q. For perfect gas sealing Do you see that 8 A. Yes 9 Q. Then if you look down under the types of wads 10 available you'll see at this time cardboard wads are 11 available correct 12 A. Yes 13 Q. And how are they packed 14 A. In box 15 Q. And you'll see premium felt wads Do you see 16 that 17 A. Yes 18 Q. Earlier you testified that premium felt wads 19 were always sold in boxes How does this say they were 222222 sold 222222 A. In box 222222 Q. On box of how many 222222 A. 500 222222 MR KARST Objection to form 25 Q. By Mr. Mort And that's consistent with your 266 1 scope of Remington's business 2 A. Correct 3 Q. Go to page five 3134 control number 4 A. have it 5 Q. Do you see a section in the upper hand 6 corner called wads 7 A. Yes 8 Q. Can you tell me do you see any felt wads still 9 being offered for sale by Remington 10 A. No. 11 Q. Is that consistent with your recollection that 12 felt wads were phased out shortly after you started in 13 1968 14 A. Yes 15 MR KARST Objection to form Assumes 16 facts not in evidence 17 Q. By Mr. Mortl From your personal recollection 18 and your personal experience when do you believe felt 19 wads were phased out 20 A. Around this time 1970 or thereabouts 21 22 Defendant's Exhibit 15 1972 23 Remington Sporting Firearms and 24 Ammunition catalog marked for 25 identification 265 12 recollection of how felt wads were sold by Remington 12 A. Yes 3 Q. I believe you testified that in 1968 or so felt 4 wads were being phased out when you started at 5 Remington 6 A. That's right 7 Q. Have you seen any document post 1968 that 8 indicates that Remington was still selling felt wads 9 A. Not that I recall 10 MR MORTL Set that one aside sir 11 12 Defendant's Exhibit 14 1/2/70 Remington 13 Ammunition Components list marked for 14 identification 15 67222222 Q. By Mr. Mortl I'm showing you what's been 67222222 ~~ marked as Exhibit 14 which is Remington Ammunition 67222222 Components list effective January 2 1970. It's got 67222222 SGP10003130 through 3137. Can you tell us what this 67222222 ~~ document sir 67222222 A. This is a components catalog of components made 67222222 _ by Remington for sale in 1970 67222222 Q. Is this a document you're familiar with 67222222 A. Yes 67222222 Q. And it's generated in the normal course and 267 1 Q. By Mr. Mortl We're almost done I have one 2 more for you We're you got Exhibit 15 which is a 3 Remington 1972 Sporting Firearms and Ammunition 4 catalog bates number SGPI 0003298 through 3345. Sir 5 can you tell us what this document is 6 A. This is a 172 Sporting Firearms and Ammunition 7 catalog from Remington what's for sale 8 Q. Now was this document generated in the normal 9 course and scope of Remington's business 10 A. Yes 11 Q. And again the general purpose of this document 12 _ is to identify the type of products that Remington was 13 offering for sale in that year 14 A. That's right 15 Q. you could go to page 30 of the document 16 control number 3327 at the bottom 17 A. Okay I have it 18 Q. And if you could actually kind of open it so you 19 can see 30 and 31 at the same time 20 A. Okay 21 Q. You'll see Introducing RXP Remington and Peters 22 New Gauge Trap and Skeet Loads Sir you referenced 322 that RXP loads yesterday Does this document help 322 refresh you on when RXP loads were first introduced to 322 the potential customers Doby Professional Reporting Inc. 952-943-1587 27 Pages 264 to 267 Raymond A. Anderson Jr. 7/19/2018 268 270 1 A. Yes 23 Q. And when approximately was that 23 A. 1972 1 loads more regularly than that 2 A. No. 3 Q. How about for the RXP line after it was 4 Q. And did the RXP replace a prior version of a 4 introduced 5 target shell 5 A. After it was introduced it was the only one 6 A. Yes it did 6 Q. I would like to take you back to Exhibit 2 from 7 Q. And what did it replace 7 yesterday 8 A. The American 8 A. Okay 9 Q. And the American is the one with the plastic 9 Q. This is that February 17 1971 document 10 basewad 10 entitled Toxicity of the Primer and the Projectile in 11 A. Plastic basewad correct 11 Rimfire Ammunition Some of this document was read 12 Q. looking at the section at the top of 12 into the record I'm not sure you got any questions on 13 pages 30 and 31 is that a section of an RXP 13 the document itself Let me ask you do you see up at 14 shell 14 the top hand corner of the first page M.W. Kordas 15 A. Yes is 15 Jr. supervisor applied research 16 Q. And there any basewad in an RXP shell 17 A. Technically no 16 A. Yes I see it 17 Q. What was the applied research 18 Q. Why is that 18 A. It was another one of several research groups at 19 A. It's all one piece 19 Remington for ammunition primarily for ammunition 222222 Q. Is that what you'll see the term in here 20 Q. When you say research what are you referring 222222 unibody 21 to 222222 A. Yes that's right 22 A. New products modified products new 222222 Q. And so the jury can understand can you 23 applications that sort of thing 222222 give them just layman's description of what a unibody | 24 Q. So potential new products would be something 222222 is 25 that they would take a look at 269 1 A. A unibody is a shotshell that's identical 2 dimensionally to its predecessors with the exception 3 that it's a piece shell and there's no separate 4 basewad It's integral with the walls of the shell 5 Q. And the Americans were target load shells 6 A. Correct 7 Q. And the RXP are target load shells correct 8 A. Correct 9 Q. Were mold basewads ever part of the 10 American shells 11 A. No. 12 Q. Were molded basewads ever part of the RXP 13 line 14 A. No. 15 Q. Were the American and the RXP after they 16 were introduced the main gauge target load lines 17 Remington sold 18 A. Yes 19 MR KARST Objection to form 222222 Q. By Mr. Mortl And how do you know that 222222 A. Experience 222222 Q. How about production in general in your 222222 experience at the plant during the time that the 222222 American gauge was being manufactured for target 25 loads was there any being manufactured for target 271 1 A. Yes definitely 2 Q. And we see toxicity of the primer and the 3 projectile in rimfire ammunition Is rimfire 4 ammunition shotgun 5 A. No. It's rimfire -- it has a rimfire priming 6 function as opposed to a centrally located separate 7 primer 8 Q. Does this document have anything to do with 9 mold basewads 10 A. Absolutely not 11 Q. It says down at the bottom of the first page 12 asbestos in the projectile 13 A. huh 14 Q. To your knowledge did Remington ever 15 manufacture ammunition that contained asbestos in a 16 projectile for an end user 17 A. No. 18 Q. Do you have any idea what they're referring to 19 here in the applied research exploratory division 20 A. I believe this was part of a development program 22222 that was purely experimental for lethal ammunition 22222 and frangible projectiles and things of that sort It 22222 was very much experimental never saw the light of day 22222 in the plant Never was really intended to be 25 produced Doby Professional Reporting Inc. 952-943-1587 28 Pages 268 to 271 Raymond A. Anderson Jr. 7/19/2018 272 1 Q. Let me ask for clarification Did an 2 containing projectile ever make the production 3 line while you were there 4 A. No. 5 Q. I'm going to switch a gears little bit sir 6 You testified I think from time to time between 7 firing ammunition in the plant as part of the testing 8 of ammunition and I think sometimes you guys would 9 have empty spent shells 10 A. Yes 11 Q. And those would include target load shells 12 A. Yes 13 Q. And those would include some target load shells 14 with mold basewads 15 A. Yes 16 Q. Have you heard of Remington Park 17 A. Yes 18 MR KARST What 22222 MR MORTL Remington Park 22222 Q. By Mr. Mortl Also in Bridgeport Connecticut 22222 A. Yes 22222 Q. Can you tell us did spent shells containing 22222 mold basewads ever go to Remington Park 2 A. Generally no but yes some did 2 Q. And was there an area of Remington Park where 274 1 16 and 17 your copies of the Plaintiff's second 2 amended notice of taking of this deposition of 3 Sporting Goods Properties Inc. and E.I. du 4 Pont de Nemours & Company Exhibit 16 is the 5 Sporting Goods notice and Exhibit 17 is -- 6 they're both your copies but Exhibit 17 is your 7 copy of the du Pont notice 8 9 Defendant's Exhibit 18 Sporting Goods 10 Properties objectiontso notice of 11 deposition marked for identification 12 13 Defendant's Exhibit 19 E.I. du 14 Pont de Nemours & Company's objections to 15 notice of deposition marked for 16 identification 17 18 MR MORTL Then I'm also going to mark for 19 identification here as Exhibit 18 Sporting 20 Goods objections to the notice and Exhibit 19 21 du Pont's objections to the notice 22 Q. By Mr. Mortl Sir as you understand it you 23 weren't produced -- there's a series of categories in 24 these documents You weren't produced as the person 25 most knowledgeable in every single category is that 273 1 spent shells were stored 2 A. Yes 3 Q. Did that have a name 4 A. Shotshell Mountain I believe 5 Q. And spent shells were sent to Shotshell Mountain 6 pretty much the whole time you worked at Remington 7 A. Yes 8 Q. And that practice was in place before you got 9 there as well 10 A. Yes 11 MR MORTL The only other thing I want to 12 do for recordkeeping -- could I have a copy of 13 the deposition notice please Let me go ahead 14 and have both of them 15 16 Defendant's Exhibit 16 Plaintiff's second 17 amended notice of deposition 18 of Sporting Goods Properties marked for 19 identification 20 21 Defendant's Exhibit 17 Plaintiff's second 2222 amended notice of deposition of E.I. du 23 Pont de Nemours & Company marked for 24 identification 25 MR MORTL I'm going to mark for Exhibits 275 1 correct 2 A. That's correct 3 MR MORTL And that's reflected in 4 objections and meet and confers and other 5 things 6 I believe that is all have I'm going to 7 take one quick break and make sure and cede the 8 chair to Mr. Karst for any further examination 9 he might have Thank you very much 10 VIDEOGRAPHER The time is 12:55 p.m. We 11 are going off the record 12 13 * 14 15 VIDEOGRAPHER The time is 1:18 p.m. We 16 are back on record 17 18 REDIRECT EXAMINATION BY MR KARST 19 20 Q. By Mr. Karst Mr. Anderson hopefully I'll be 21 the last one to ask you questions today and then we'll 22 be finished 23 First of all when you were being asked 24 questions by your attorney -- strike that 25 I had asked you this morning when we first got Doby Professional Reporting Inc. 952-943-1587 29 Pages 272 to 275 Raymond A. Anderson Jr. 7/19/2018 276 - here if from yesterday's deposition to this morning if 2 you had reviewed any documents and you told me no 3 correct 4 A. Correct 5 Q. But in your deposition today when your attorney 6 was just asking you questions you said quote last 7 night I was going through some stuff 8 MR MORTL Misstates testimony 9 Q. By Mr. Karst That's word for word what you 10 stated I want to know what did you go through last 11 night because earlier you said you didn't 12 A. Could you give me some context for the comment 13 Q. He was show you the catalogs I'm not sure 14 which specific catalog but he was showing you all 15 these different catalogs that he had marked as 16 exhibits 10082 A. I don't recall going through anything for the 10082 this proceeding 10082 Q. I'm only ask because you said it 10082 MR MORTL Misstates testimony 10082 THE WITNESS I don't know I don't 22 recall I don't recall what I was doing with 2 that with anything to do with this 24 Q. By Mr. Karst So your statement last night 2 going through some stuff you're now stating that you 278 1 seen ? 3 A. I saw cover page that had Benson's name on it Q. Mr. Benson in his deposition that lasted a 4 couple days when we took his deposition up in the 5 hospital up in Alaska he never mentioned in any of his 6 depositions ever working with plastic wad or power 7 piston wad so I can state that for a fact that he 8 never testified to anything like that Your testimony 9 regard to all of the catalogs that your attorney was 10 showing you the majority of them referred to power 11 piston wads okay Would your testimony about that 12 just be limited as your attorney was asking you just 13 to the shotgun shells that had the power piston wads 14 since that's what you were asked about in these 15 catalogs MORTL specific MR : ObjeOcbtjieocntion Vague Vague OvOevrebrrbrooaadd 17 Misstates the record 18 WITNESS THE I'm not sure I understand what you're asking me testimony 20 Q. Mr. Karst Your testimony that -- your you you 2 laototkoirnngeywas speciftihceally askipnigston antdhesmhowing power catalogs and the diagrams these cutouts that you were 23 at all had in Is that 24 recollection of what your attorney was showing 3 showing yyoouur 277 1 didn't go through some stuff last night 2 A. Not specifically for this proceeding no I did 3 show my deposition from the previous proceeding to my 4 wife in part I don't remember whyI did that She 10 was asking me about it I think that was it from what 6 I said this morning It wasn't anything to do with 7 this 8 Q. Earlier you were making notations on one of 9 exhibits that Counsel gave you You were okay 10 handwriting those as you were holding your pen for a 11 good good ten minutes or so 12 A. I think I was putting initials on there Is 13 that what you're talking about 14 Q. Yes When you were writing on the exhibit 15 A. Yes 16 Q. And you were okay doing that 12222 A. I was but if you look at them they're not very 12222 legible 12222 Q. I'll ask this one again Have you ever read a 12222 summary of my client's testimony Mr. Benson 12222 MR MORTL Ask and answered 12222 You can answer again 12222 THE WITNESS I don't believe I've read it 24 no I've seen it but I haven't read it 12222 Q. By Mr. Karst What do you mean you haven't 279 1 A. As I recall it was yes 2 Q. Okay My client never talked about working with 3 or shooting loads that ever had the power piston 4 A. Okay 5 Q. So my question to you is was your testimony 6 when you're talking about these specifically limited to 7 the shells that had the power pistons since that's 8 what he was specifically asking you about 9 MR MORTL Objection to form Overbroad 10 Vague Misstates the record and the Plaintiff's 11 testimontestyimony 12 THE WITNESS My recollection of that part 13 of my testimony was that I was asked to point 14 out the various components that make up the 15 shotshell and the ones that I was asked about 16 had the power piston in it 17 Q. By Mr. Karst Correct Can you give me the 18 components of a rimfire ammunition 19 MR MORTL Objection to form Overbroad 20 THE WITNESS Did you say a rimfire 21 ammunition 22 Q. By Mr. Karst Rimfire ammunition can you give 23 me the components of it 24 A. Do you mean a rimfire cartridge 25 Q. Yes Doby Professional Reporting Inc. 952-943-1587 30 Pages 276 to 279 Raymond A. Anderson Jr. 7/19/2018 280 1 MR MORTL Same objection 2 Q. By Mr. Karst Yesterday you said you don't use 3 the word cartridge so that's why didn't want to use 4 it 5 A. I don't use it for shotshells 6 Q. Can you give me the components -- 7 A. From rimfire 8 Q. Right From the bottom to the top the point of 9 the bullet 10 MR MORTL Same objection 11 THE WITNESS Case shell case primer 12 powder projectile 13 Q. By Mr. Karst Anything else 14 A. No. 15 Q. What's the case made out of 16 A. Brass 17 Q. Any reason anything else would be in there by 18 the primer 19 A. Any reason anything else would be in there by 20 the primer Is that what you said 21 Q. Yes 22 A. No. 23 Q. The letter that was marked as Exhibit 2 talks 24 a_bout asbestos being used in this projectile correct 25 A. Yes as I read it 282 1 the director at Haskell Laboratory at du Pont correct 2 A. Yes 3 Q. And this letter is dated January 19 1971 4 A. That's right 5 Q. And if you look at Exhibit 2 which is on your 6 right that specifically says in the first sentence 7 You letter of January 19 1971 to Dr. Zapp was given 8 me for comment Do you see that 9 A. Yes 10 Q. Any reason to believe that this letter Exhibit 20 was not the precursor letter to Exhibit 2 12 MR MORTL Objection 13 Q. By Mr. Karst Do you have any reason reading 14 these to think that that's not true 15 MR MORTL Objection to form Compound 16 Foundation Calls for speculation 17 THE WITNESS It looks to me like they 18 follow 19 Q. By Mr. Karst As you can see on Exhibit 20 20 you'll see on the bottom they're talking about the 21 projectile is a friable composition of and it says 22 weight by percentage 36 percent asbestos 53 percent 23 wood fiber 7 percent wax and butyl rubber 1 percent 24 paraffin 3 percent water Do you see where I'm 25 reading that 281 1 MR KARST Here is the precursor letter 2 We can mark it as Exhibit 20 3 4 Plaintiff's Exhibit 20 1/19/71 letter to 5 Dr. J.A. Zapp Jr. from M.W. Kordas 6 Jr. marked for identification 7 8 MR KARST This is actually from a du Pont 9 document production You'll see the bates stamp 10 in the lower hand corner 11 MR MORTL Do you have an extra copy by 12 chance 13 MR KARST I do 14 Q. By Mr. Karst This is the letter that caused 15 the response that you read in Exhibit 2 16 MR MORTL I'll object to the extent 17 Counsel is testifying 18 Q. By Mr. Karst Okay 19 A. Yes 222222 Q. As you can see this letter is from Mr. Kordas 222222 Mr. Kordas you stated worked at Remington 222222 A. Correct 222222 Q. And this is on Remington letterhead correct 222222 A. Yes 222222 Q. And he's writing this letter to Dr. Zapp who's 283 1 A. Yes 2 Q. Did I read that correctly 3 A. Yes 4 Q. Is that roughly the same type of mixture that a 5 basewad is made out of in shotshell 6 MR MORTL Objection 7 Q. By Mr. Karst Primarily being asbestos and 8 wood fiber as you mentioned 9 A. It has several of the same ingredients That's 10 as far as I would take it 11 Q. And as we saw yesterday in the patent by your 12 friend from Remington these percentages are within the 13 tolerances of that patent correct 14 A. I don't recall that 15 MR MORTL Objection to form 16 Q. By Mr. Karst We can pull out the patent 17 which is Exhibit 3 18 A. Okay 19 Q. Here is Exhibit 3. As we look right down here 20 where I'm pointing it says -- 21 A. I remember reading that yesterday 22 Q. Asbestos not substantially less than 30 percent 23 and not substantially more than 60 percent 24 A. Okay 25 Q. And this letter that you're looking at Exhibit Doby Professional Reporting Inc. 952-943-1587 31 Pages 280 to 283 Raymond A. Anderson Jr. 7/19/2018 284 286 1 20 is 36 1 Q. Even when it's talking about the primer 2 A. Okay 2 A. It says the projectile Yes The projectile is 3 Q. Also mixed with wood fiber which is like I 4 said in this letter of Exhibit 20 53 percent 3 a friable composition ofthe following The projectile 4 is the bullet or would be analogous to the bullet It 5 A. huh 6 MR MORTL Objection to form 5 might not be a bullet in the normal of sense the term 6 Q. Wouldn't the projectile be the whole thing 7 THE WITNESS Okay And 7 A. No. The projectile is what gets ejected by the 8 MR MORTL There's no and He'll ask you 9 if he's got another question 10 THE WITNESS Okay 11 Q. By Mr. Karst Now this letter is talking 8 powder whatever the cartridge is 9 Q. So you're telling me your read of this is that 10 the asbestos and the wood fiber is at the edge the 11 bullet 12 about the primer Is the primer on a rimfire 12 A. That's what the bullet's made out of 13 ammunition relatively the same position as it is on 14 shotshell Is that the end of the -- 13 Q. So you're saying the bullet itself made out 14 asbestos 1715 A. Yes But located in the peripheroyf the shell as opposed to in the center of the primer the edge Right that's difference It's the 18 of the shell as opposed to directly in the centcenter er but edge 19 but it's in the same position on the overall cartridge 20 or shell correct 21 A. Yes 15 A. It's made out of a compound containing asbestos 16 yes That's what this says 17 Q. Just so we're 100 percent clear- 18 A. It's a friable projectile which this mixture 19 would be if you fired it at the speed of a bullet or 20 anything close to it Q. So you're saying that the actual bullet is not 2222 Objection |22 metal comes out this . 2 A. That's correct This is not -- So would 2222 THE WITNESS Yup 24 Q. Hold on -- and that you're actually firing a 25 Q. Q. By Mr. Mr. Karst you agree with me that 25 composition of wood fire and asbestos out of the gun 285 1 the composition of the material they're talking about 2 related to the primer would be in the same end of 3 the ammunition on this piece of ammunition as it is on 4 shotshell which would be the end 5 MR MORTL Objection Form Overbroad 6 Vague Ambiguous Speculation 7 THE WITNESS I agree with my counsel I 8 don't know what you're asking me I don't 9 understand what you're asking me 10 Q. By Mr. Karst I'm asking you if this mixture 11 the asbestos mixture if it's by the primer that has 12 be at relatively the same position in this 13 ammunition as it on a shotshell which would be at 14 the end of the shell correct 15 MR MORTL Objection Form Vague 16 Ambiguous Foundation Speculation 17 If you know 18 THE WITNESS If understand what I'm 19 reading right they're on opposite ends The 20 projectile is the part on this one that has this 21 composition 22 Q. By Mr. Karst So you're saying that in your 23 reading of this the asbestos component is out by the 24 bullet 25 A. Yes 287 1 and not a piece of metal 2 A. That's what this says to me I recall vaguely 3 this time period and what was going on This was a 4 very experimental project 5 Q. So you remember this project 6 A. Vaguely yes Friable bullets were a project in 7 the exploratory research group 8 Q. Why 9 A. Primarily for riots and crowd control and that 10 kind of thing because they're lethal 11 Q. Why would they use asbestos in a friable bullet 12 MR MORTL Objection Foundation 13 Speculation 14 THE WITNESS No clue 15 Q. By Mr. Karst Who worked on the project 16 A. Let's see what the names are here It looks 17 like Marty Kordas 18 Q. Who's Marty Kordas 19 A. Marty Kordas is the supervisor of this research 20 group that had this project 21 Q. Because earlier when I asked you in your 22 deposition I said if asbestos was being used and you 23 told the only place it was used was the 24 containing basewad but now you're changing 25 your testimony that it was used also in this Doby Professional Reporting Inc. 952-943-1587 32 Pages 284 to 287 Raymond A. Anderson Jr. 7/19/2018 288 123 MR MORTL Objection Argumentative 123 Misstates testimony Form 123 Q. By Mr. Karst So now we have products that 4 contained asbestos that Remington made not one 5 correct 6 A. No. 7 MR MORTL Misstates testimony 8 Q. By Mr. Karst What are you saying You tell 9 me 10 A. I'm telling you an experimental product was made 11 that apparently had asbestos as a constituent in the 12 projectile 13 Q. And how do you know this was experimental 14 A. Because I was there They did all kinds of 15 things like this I remembtehart project for friable 16 bullets They used all kinds of materials They tried 17 lot of things 18 Q. And you specifically remember that the friable 19 bullets they tried contained asbestos 222222 didn't 222222 many 222222 Q. What other combinations did they have 222222 A. They had different metal powders They had 24 clays They had ceramics Beyond that I can't be more 25 specific Generally that's the kind of thing they 290 1 late 70s 2 Q. By Mr. Karst Do you know where he lived 3 roughly 4 A. In Fairfield I don't know where 5 Q. If you could read Exhibit 2 please which is 6 letter 7 A. Okay 8 Q. The bottom the section that says asbestos in 9 the projectile 10 A. Yes 11 Q. About halfway through the sentence starts with 12 the projectile Are you there 13 A. Yes It says the projectile we estimate and so 14 forth projectile described friable is 15 Q. Yes The descridebscreibded as friable We 16 judge from this description that the asbestos could 17 be reduced by friability to discreet fibers and 18 disbursed at least to a partial extent in the air of the enclosure 20 in which the firing is done A. Okay 22 Q. that talking about the actual barrel the ? Foundation : 23 Speculation Foundation Form . : don't 25 THE WITNESS I don't really know 289 1 used 2 Q. Who else worked on this project 3 MR MORTL Objection Foundation Form 4 THE WITNESS I don't recall 5 Q. By Mr. Karst In the upper hand corner 6 of Exhibit 20 do you know D.S. Foote or L.J. Scott 7 A. Yes I knew both of them 8 Q. What is Mr. Foote's full name 9 A. Donald S. Foote 10 Q. And Mr. Scott 11 A. Lawrence J. Scott 12 Q. And what did Mr. Foote do at Remington 13 A. He was the director of a research group 14 research department at Remington 15 Q. Mr. Scott 16 A. He was a manager reporting to Mr. Foote 17 Q. Are either of them alive today 18 A. Mr. Foote is not I know for sure Mr. Scott I 19 don't know 20 Q. When was the last time you saw Mr. Scott 21 A. When I was at Remington 22 Q. About how old would he be today 23 MR MORTL If you know 24 THE WITNESS He was little older than I 25 am maybe five years That would put him in his 291 1 Q. By Mr. Karst What else could that be 2 MR MORTL Same objection 3 THE WITNESS I don't know It could be 4 the range that it's fired in 5 Q. By Mr. Karst What do you mean 6 A. There's a range -- we had ranges at Remington 7 firing ranges that were basically concrete tunnels 8 It could be in that It could be the enclosure in 9 which the firing is done 10 Q. So we could be talking on the range of where the 11 firing is done or the actual enclosure of the gun 12 itself It could be one or the other Fair 13 MR MORTL Objection Misstates 14 testimony Speculation 15 THE WITNESS I wouldn't say it would refer 16 to the gun but that's just an opinion 17 Q. By Mr. Karst On that letter there's Dr. John 18 A. Zapp I had asked you yesterday if you were aware 19 who Mr. Zapp was If told you he was the director of 20 toxicology and industrial medicine at du Pont at 2222 Haskell Laboratory does that help bring any 2222 _ recollection to you 2222 A. No. I don't know who he was I never met him 24 Q. On the bottom of the second page I asked you 25 yesterday if you knew who James F. Morgan was Doby Professional Reporting Inc. 952-943-1587 33 Pages 288 to 291 Raymond A. Anderson Jr. 7/19/2018 292 123 MR MORTL Which exhibit 123 MR KARST Same exhibit 123 MR MORTL ? 4 MR KARST Correct 5 MR MORTL He's looking at the wrong one 6 THE WITNESS Exhibit 20 7 MR KARST 2 8 MR MORTL That's why I asked I'm going 9 to take away 20 just for a minute I'll put it 10 back if you need it 11 Q. By Mr. Karst Second page bottom 12 A. Second page bottom James F. Morgan Okay 13 What is the question If 14 Q. told you that Mr. Morgan - yesterday you 15 mentioned that you don't know who Mr. Morgan was If 16 told you he was an employee of Haskell Lab in the 17 industrial hygiene department at du Pont does that 18 help bring back any recollection as to who he is A. No. Q. On the top of the first page I had asked you 22222 yesterday - at the very very top you'll see a BCC 22222 A. Yes 22222 Q. This was blind copied to a C.A. D'Alonzo MD medical division 25 A. huh 294 1 A. I don't recall That's what I'm trying to 2 remember I'm sorry I don't 3 Q. Yesterday you mentioned that you had -- I don't 4 want to put words in your mouth I believe you said 5 that you were unaware of any testing that was done to 6 determine any asbestos fiber release when firing a 7 shotshell that had an containing basewad 8 You're unaware of any testing correct 9 A. am unaware of any 10 Q. Have you ever heard of any testing in that 11 regard being done by either Remington or du Pont 12 A. No. 13 Q. testing on something like that was done 14 typically would that be done at Remington or would that 15 be done at du Pont 16 MR MORTL Objection to form 17 Speculation 18 you know 2 THE WITNESS If involved firing a gun 2 firing some ammunition off it would have been 2 done at Remington 2 Q. By Mr. Karst Are there specific people in the 60s and 70s at Remington who would have done those type 2 ofexperiemxepenrtisments objections 2 MR MORTL Same objections 293 1 Q. If told you he was the assistant medical 2 director at du Pont does that help bring back any 3 memory as to who he is 4 A. No. 5 Q. Exhibit 20 this is Mr. Kordas's letter On the 6 second page below his signature on the left you'll see 7 his initial MWK 8 A. Yes 9 Q. And then CML 10 A. Yes 11 Q. I'm assuming that's the person who dictated -- 12 he dictated the letter and they typed it That's my 13 assumption Would that be a fair assumption 14 MR MORTL Objection Foundation 15 If you know 16 THE WITNESS My answer is we didn't 17 usually do things that way not supervisors 18 anyway Maybe the higher 19 Q. By Mr. Karst Do you know who CML is 222222 A. No. 222222 Q. Any staff that you're aware of that Mr. Kordas 222222 had that would have the initials CML 222222 A. I'm trying to think of who his secretary was 222222 No I don't know 222222 Q. Do you know who Mr. Kordas's secretary was 295 1 THE WITNESS It would have been the group 2 that we were just talking about 3 Q. By Mr. Karst Mr. Kordas 4 A. Exploratory research or applied research Mr. 5 Kordas might very well have been involved yes 6 Q. So someone like Mr. Kordas Mr. Foote or Mr. 7 Scott 8 A. Not Mr. Foote or Mr. Scott 9 Q. Okay That's why want to make sure we're on 10 the same page Anybody else besides Mr. Kordas that 11 you can think of who would have either been in charge 12 of or assisted in that type of research if it was 13 done 14 MR MORTL Objection Form Assumes 15 facts Calls for speculation 16 THE WITNESS I can't think of anybody 17 MR KARST I think that's all the 18 questionsI have 19 MR MORTL We don't need to move I just 20 have a couple very short questions for you 21 22 EXAMINATION BY MR MORTL 23 24 Q. By Mr. Mortl The target load shells that 25 contained the mold basewad that was encased in Doby Professional Reporting Inc. 952-943-1587 34 Pages 292 to 295 Raymond A. Anderson Jr. 7/19/2018 296 123 plastic and the power piston - so these are shells 123 from the 1960s some period in the 1960s If a shooter 123 was going out on a shooting range and picking up spent 4 shells would power after it had the piston still be in that shell been fired ? 7 Q. So if the shooter went out and picked up that 8 shell would there be anything to prevent that shooter 9 from reloading that original power piston shell that 10 contained a mold basewad with a different type of 11 wad in the reloading process such as a felt wad or an H 12 wad 13 A. Different from the power piston 14 Q. Yes 15 A. No. They could dothat 16 MR MORTL I have no other questions 17 Does anybody on the phone have any questions 18 Thank you The deposition is concluded 19 MR KARST Are you guys going to read and 22282 sign or waive signature 22282 MS TRATTLES Waive it 22282 MR MORTL We'll read and sign but we'll 22282 waive it so you don't need to wait on that if 22282 that's your question If you want to be able to 25 use the deposition - 297 123 MR KARST Okay 2 VIDEOGRAPHER The time 1:47 p.m. The 123 deposition of Ray Anderson is now conduded conduded and 4 we are going off the record 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 222222 222222 222222 222222 222222 222222 2 STATE OF CONNECTICUT 3 , Keli McGilton a Notary Public in and for the State of Connecticut do hereby certify that there came 4 before Murtha Cullina CityPlace Asylum 5 Street Hartford Connecticut the following named truth as to his knowledge touching and concerning the 7 matters in controversy this cause that was 8 thereupon and statement examination true record of the testimony given the witness to 10 my by the best of knowledge and ability I further certify that I am not a relative or 11 nor employee employee parties parties 12 financially interested in the outcome of the action this WITNESS MY HAN2D 3nd day July 2018 156 156 17 Keli McGilton Notary Public 1222222 1222222 12 2 2 1222222 12 2 2 My Commission expires 25 July 31 2022 298 Doby Professional Reporting Inc. 952-943-1587 35 Pages 296 to 298 Raymond A. Anderson Jr. Page 299 A a.m 10,15 ability 298 able 296 absolutely 222 244 271 accuracy 244 accurate 263 accurately 251 acronym 211 action 298 actual 217 221 226 247 261 286 290 291 ad 186 added 207 addition 224 additional 224 ads 186 adversarial 212 advertise 186 187 187 advertised 187 advertising 187 188 188 198 age 184 ago 185 214 244 agree 284 285 agreeable 168 215 ahead 236 4,17 254 273 aid 3,14 aids 259 aiming 230 air 290 AL 163 Alaska 278 alive 2,15 186 197 215 289 American 182 258 1,19 261 261 262 268 10,15,24 Americans 262 269 allow 242 allowed 256 Ambiguous 6,16 amended 166 167 168 17,22 274 American 187 ammo 187 228 ammunition 7,8,9,13 17,18,20,22 173 173 15,20 188 190 2,8,25 219 220 231 14,23 232 233 234 2,22 254 6,11,13 21,25 8,17 13,17 266 267 267 11,19,19 3,4,15,21 272 18,21,22 284 285 3,3,13 294 amorti@glynnfinley.com 164 amount 224 249 analogous 286 Anderson 163 166 168 169 216 275 297 298 Andrew 164 216 animal 225 announced 258 announcement 218 annual 10,18,21,24 219 232 234 254 260 263 annually 218 219 232 answer 171 176 184 201 215 277 293 answered 171 277 anybody 169 184 186 189 6,17 214 10,16 296 anyway 293 apologize 242 apparently 288 appearances 1,16 165 168 appears 221 Appliances 165 applications 270 applied 15,17 271 295 approximately 268 area 192 195 196 196 15,16,17 242 244 272 areas 184 Argumentative 288 Arkansas 16,16,20,23 16,16,20,23 208 4,14,17 210 210 211 arm 172 Arms 3,9,15 3,21 258 arrived 211 227 arrow 221 239 242 arthritis 217 239 asbestos 9,15 171 13,21 22,23 1,20,21,23,24 196 4,13 207 208 208 212 224 224 3,6,9,12 12,15 280 282 7,22 285 285 286 10,14,15,25 11,22 288 4,11,19 8,16 294 containing 170 171 272 287 294 asbestos 208 11,20 14,25 aside 231 233 238 260 262 265 asked 171 213 215 217 255 275 23,25 278 279 15 287 18,24 18,24 292 20 asking 276 277 278 19,21 279 285 285 assembled 252 assembly 190 assigned 188 193 assistant 293 assisted 295 associate 240 associated 217 231 6,12 236 assume 169 Assumes 266 295 assuming 169 230 293 251 254 | assumption 179 293 293 Bass 185 bates 267 281 Asylum 163 168 298 BBs 228 246 BCC 292 attachment 200 bears 232 attendance 165 215 attended 198 Beckerdite 9,11,22 199 205 attending 194 attends 193 beginning 253 behalf 168 attorney 216 217 275 276 9,12 21,24 attorney's 169 attorney 215 attorneys 9,14 201 208 215 belief 244 believe 176 178 179 11,14 182 184 188 196 7,12 210 213 218 223 224 227 235 249 automated 252 265 266 271 available 8,9,182,9,12 227 233 235 273 275 277 282 294 245 256 258 259 10,11 Avenue 9,13 aware 171 184 186 benefits 1,13 247 Benson 163 164 168 248 277 278 11,17 16,18 189 11,15 13,17 198 12,15,22 201 204 10,13,15 24,25 5,6,13,14 5,6,13,14 18,22,23 18,22,23 209 12 209 213 2,5,9 10,16,18 215 235 291 18 293 awhile 207 Benson's 207 208 214 278 best 170 189 9,15 298 better 227 228 236 251 Beyond 288 big 179 189 bigger 202 biggest 255 Bill 189 196 binder 202 9,16 225 O 213 back 180 187 202 204 208 211 16,25 224 241 244 245 15,18 270 275 10,18 293 backtrack 180 bags 177 178 179 179 Bank 165 barrel 177 230 245 8,14 290 base 186 221 based 179 220 basewad 170 171 23,23,25 2,7,8 19,23,2195,23,25 222 223 11,13 230 10,11 231 236 3,5,6,9,15 16,19,22 5,11 241 23 15,24 248 249 252 18,24 255 257 12,19,21 23,25 1,9,11,14 10,11 10,11 268 269 283 287 294 295 296 basewads 3,11 14,23 172 181 195 223 224 23,25 9,22 249 252 9,12 271 14,23 basic 4,25 252 basically 202 291 basis 180 234 bins 11,13 Bisignano 212 213 bit 180 213 230 255 256 272 black 175 202 BLACKWELL 164 blank 187 blew 231 blind 292 blow 244 blowback 3,15 244 245 blue 174 175 192 192 bodies 239 258 259 body 181 17,20 227 2,20 229 230 1,10,14 236 22,22 247 262 book 203 204 books 203 204 bore 243 bottom 170 220 221 232 234 19,20 241 2 245 246 4,12 259 261 263 267 271 280 282 290 291 11,12 Boulevard 165 bound 19,20 box 173 4,23 178 181 14,21,22 boxes 177 178 23,24 14,17 264 Brass 280 break 173 14,20 216 223 22,23 253 275 Bridgeport 170 171 189 193 200 4,13,24 201 22,25 22,25 210 15,23 211 213 272 bring 212 291 292 293 broad 183 209 219 248 249 brochure 204 broken 184 brought 212 building 18,21 bullet 5,7,13,18 224 225 227 228 239 241 280 285 4,4,5 11,13,19,21 287 bullet's 286 bullets 287 16,19 burned 229 247 buring 224 business 182 218 232 234 238 254 258 260 263 266 267 butyl 9,13 225 282 A 199 D 200 C.A 292 CA 164 call 175 191 211 225 228 238 244 246 called 16,16 188 199 8,10 266 calling 235 246 Calls 282 295 cameraman 168 Canadian 199 cancer 214 Canvas 179 cap 181 230 8,10 246 Carbide 165 10,12 cardboard 4,23 177 178 23,24 198 264 career 252 carefully 178 Carey 20,21,24 Carondelet 164 cartridge 165 279 280 284 286 case 170 190 207 207 9,19 214 214 4,11 225 11,11,15 cases 214 241 248 catalog 13,17,22 253 254 260 14 261 263 265 266 267 276 cataloged 201 catalogs 217 254 15,24 261 276 276 278 9,15,22 categories 274 category 185 274 cause 248 298 Doby Professional Reporting Inc. 952-943-1587 Raymond A. Anderson Jr. 7/19/2018 Page 300 caused 281 Caution 195 cede 275 center 164 16,18 centerfire 207 centrally 271 ceramics 288 certain 177 certainly 183 253 Certainteed 200 certified 168 certify 3,10 cetera 217 chair 275 chance 281 change 173 176 257 changed 174 175 176 193 207 219 229 252 changing 287 charge 212 295 child 178 children 214 chip 223 chips 222 chose 248 CHRISTINE 165 christine.delaney@little christine.delaney@little 165 circulation 187 CityPlace 163 298 Civil 163 clarification 272 clays 288 clean 207 clear 201 217 240 286 clearly 256 client 279 client's 277 close 202 286 closed 197 closure 228 clue 287 CML 293 9,19,22 coded 258 Coding 166 8,15 collar 192 collars 192 Collectively 188 color 166 2,18 8,15 258 coloring 174 175 coloring 174 Colton 14,16,17,22 196 6,10 6,10 223 column 245 combinations 288 come 198 218 219 251 comes 230 244 286 comfortable 219 232 254 coming 199 211 223 231 234 comment 276 282 Commission 298 committees 212 common 172 187 207 companies 198 company 8,14 164 167 199 14,15,18,22 212 258 273 274 Company's 167 274 compare 256 compared 204 compensation 2,7,10 competitions 256 completely 230 245 259 component 176 177 1,2,2 179 180 180 222 10,17 241 242 250 252 263 285 components 18,20 173 177 179 181 188 190 191 19,22 19,22 245 2,21 263 263 13,18,21,21 279 18,23 280 composition 2,6,7 282 1,21 286 286 compound 172 282 286 compulsory 211 computers 251 concentration 244 concem 212 concerned 191 concering 298 concerns 212 concluded 296 18 297 concrete 291 conducted 10,18 208 confers 275 confined 244 confusing 246 Connecticut 163 168 168 170 184 272 1,3,5 connection 233 conscious 194 consist 258 consistent 17,21 251 259 261 262 264 266 consistently 172 constituent 288 11 construct 191 construction 222 225 226 16,18,20 228 229 1,10 235 2,14 240 262 Consult 191 contact 208 245 14 258 contacted 208 215 contained 221 236 257 259 261 271 4,19 295 296 container 243 244 containing 272 286 contains 242 context 276 continuation 168 continued 163 165 167 218 contracted 217 control 220 232 5,19 238 253 254 257 261 3,23 266 267 287 controversy 298 conversations 201 copied 292 copies 274 copy 250 273 274 281 comer 220 239 241 266 270 281 289 corporate 6,11 Corporation 164 165 correct 169 170 3,4,15 172 173 175 179 181 188 189 193 195 200 24,25 211 214 217 218 219 223 3,18,23 225 226 3,17,23,24 3,17,23,24 1,19 2,21 234 236 9,12 237 5,7,11,25 21,23,25 21,23,25 244 7,25 247 249 13,16,18 250 12 252 254 257 259 263 264 266 268 6,7,8 275 276 279 280 281 22,23 282 283 284 285 286 288 292 294 correctly 283 correspondence 199 199 cost 256 counsel 168 169 250 277 281 285 attomey 298 country 184 County 163 168 couple 193 203 214 217 222 278 295 course 218 232 234 238 252 254 258 260 263 265 267 court 163 9,15 196 cover 202 278 created 217 Creek 9,10 crimp 16,18 229 246 3,10 248 248 249 CROSS 166 EXAMINATION 216 section 221 224 21,22 229 237 239 241 245 247 254 255 19,23 268 268 sections 262 crowd 287 CROWELL 164 Cullina 163 168 298 cursive 21,23 customer 183 17,18,19 2,23 256 customers 15,24 183 185 186 219 260 267 cutouts 278 cylinder 178 239 cylinders 178 D D 166 D'Alonzo 292 D.S 289 dangers 194 dash 251 date 168 dated 257 282 dates 217 14 227 day 271 4,13 day 210 days 278 Dayton's 183 DC 164 de 163 7,22 167 167 273 4,14 dealer 232 dealers 166 231 232 dealing 183 deals 218 debris 231 244 245 decades 183 deceased 209 Defendant 17,22 2,7,16 Defendant's 166 167 218 231 233 5,10 5,10 250 253 257 260 262 265 266 273 273 9,13 Defendants 163 164 165 Define 183 213 definitely 205 271 deformed 17,19 deforming 243 degenerate 230 degree 191 DELANEY 165 dent 222 department 1,21,23 8,11 200 206 289 292 depends 203 depicts 251 deposition 163 166 3,5,6 168 11,18 214 215 215 222 228 238 246 273 17,22 2,11,15 276 277 278 287 18,25 297 depositions 278 describe 252 described 178 185 221 290 description 181 14,20,22 8,21 239 247 262 268 290 design 191 194 259 designation 174 designed 190 230 1,24 14,17,21 252 Designer 189 designers 190 destroy 249 detail 239 255 deterioration 241 247 determine 294 development 271 diagnosed 213 214 diagram 229 255 diagrams 278 dictated 217 11,12 die 222 difference 174 176 284 differences 212 255 different 2,12,13,21 173 15,1165,16 176 12,13,14 3,10 14,15,18,20 181 181 19,2139,23 255 276 288 10,13 differently 177 Digest 187 dimensionally 202 269 direct 166 169 234 directly 183 185 186 284 director 282 289 291 293 disbursed 290 discharged 237 discreet 290 discuss 199 207 215 discussed 245 246 250 discussing 236 discussion 225 discussions 199 224 distributed 218 distributors 219 district 163 9,10 disturb 252 disturbed 249 division 271 292 DMBW 240 docket 168 document 218 7,21 227 231 6,9,13 21,24 3,15 7,19 235 238 241 243 245 253 254 256 257 8,18,21 259 12,20 261 261 4,15 265 265 20,23 267 5,8,11,15 267 270 9,11,13 271 281 documents 169 208 208 217 22,23 220 234 238 254 260 274 276 doing 203 207 276 277 Donald 289 dozen 187 dozens 22,24 203 Dr 167 5,25 282 Doby Professional Reporting Inc. 952-943-1587 Raymond A. Anderson Jr. 7/19/2018 Page 301 291 drawing 187 drive 166 250 mold 3,11 171 14,23 172 181 226 230 231 236 15,22 247 249 252 257 259 261 262 191 192 18,21,25 expensive 256 financially 298 7,8,22 212 218 219 223 experience 189 219 | find 201 230 248 4,18,21 fine 246 empty 180 249 272 266 21,23 finest 224 | emugaas@meagher.com | experienced 231 165 experimental 21,23 finish 245 finished 169 244 encapsulated 240 287 10,13 275 encapsulating 240 experiments 231 FINLEY 164 encased 295 294 fire 229 243 286 269 271 14,23 295 296 molded 170 182 195 221 222 223 224 6,9,15 16,20,22 248 249 252 255 enclosed 5,11 255 enclosing 18,24 enclosure 241 290 8,11 encyclopedia 13,14 13,14 encyclopedias 204 11 ends 220 285 expertise 190 expires 298 explain 221 229 exploratory 271 287 295 express 233 235 extent 281 290 firearms 13,17,21 2,22 254 6,11 260 266 267 fired 4,9,18 230 231 237 247 248 286 291 296 269 du 163 7,22 167 167 168 14,17 188 14,23 11,19,23 191 3,8,9,17,21,25 14,20 7,12,16 194 195 201 202 8,11 214 214 217 273 3,7,13,21 281 282 291 292 293 11,15 duly 298 dust 196 212 222 13,17 231 244 245 dusting 231 DW 240 E 163 2,23 166 G 199 R 189 E.I 163 7,22 167 167 273 3,13 Eagle 165 earlier 175 207 237 257 264 276 277 287 earliest 171 early 7,10 176 207 easier 173 187 easy 212 241 edge 284 286 effect 13,16 effective 220 232 234 263 265 Egleston 15,16 either 172 201 214 215 244 10,12 289 294 295 ejecta 229 230 ejected 229 8,11,11,12,15 229 13,18 247 11,12,13,11,412,13,14 286 eliminated 245 eliminating 245 ELLIOT 165 ELLIOTT 165 Elmo 165 embossed 202 employed 189 employee 19,19 192 193 197 223 292 11,11 employees 188 15,18,21 24,25 190 engineer 189 210 engineering 189 190 194 engineers 210 ensure 258 ensuring 241 entirely 180 entitled 220 232 254 257 270 epk@karstvonoiste.com 164 Erik 164 168 Ervine 189 Ervine's 189 escaped 229 escaping 225 ESQ 4,10,14,19,24 4,10,14,19,24 4,9,18 estimate 290 et 163 217 eventually 248 everybody 168 195 evidence 231 266 exact 203 227 exactly 241 243 examination 169 275 275 298 examined 298 example 170 177 219 exception 269 exclusive 221 8,15,19 224 225 227 228 245 exerted 222 exhibit 7,8,9,10,12,13 166 14,17,18,20,21,23 14,17,18,20,21,23 2,4,6,8 169 16,23 216 217 218 220 227 231 232 233 234 5,10 1,21 17,20 19,24 19,24 1,18,21 255 256 6,13 5,10 262 20,25 12,17 266 267 270 16,21 274 6,9,13,19,20 6,9,13,19,20 277 280 2,4,15 282 282 10,11,19 17,19 283 284 289 290 1,2,6 293 exhibits 166 1,10 273 276 277 exist 201 205 existed 203 existence 193 207 expand 211 expect 169 extra 240 281 F F 165 291 292 N 200 fabrication 222 face 244 facility 170 171 188 190 193 4,14 201 208 208 4,14,17 6,7,15,24 3,5,6 211 212 6,25 6,25 214 216 fact 180 207 244 278 facts 266 295 fail 248 failed 249 failing 248 fair 203 213 224 291 293 Fairfield 290 fairly 187 230 familiar 200 219 232 254 260 263 265 famous 264 far 176 179 190 24,25 262 283 farther 235 faster 259 feature 259 features 243 February 270 Federal 165 feeling 216 felt 177 178 9,12 13,15,17,18 13,15,17,18 226 3,6,9,15 229 3,20 231 242 245 250 15,18 1,3,8 266 8,12,18 296 fiber 19,21 282 283 284 286 294 fibers 225 230 290 field 170 2,7,19,23 1,12,16,17 175 10,18 181 220 22,24 228 22,25 229 233 figured 198 File 163 filed 168 files 2,3,8 filled 203 filler 9,11 firing 12,21 231 272 286 290 7,9,11 294 6,19,20 first 169 182 220 235 13,22 248 249 258 267 270 271 275 275 282 292 firsthand 201 206 five 263 266 289 eighths 230 minute 216 Flint 200 flip 171 232 243 263 flippant 215 Flipping 245 floor 223 flour 224 flyer 166 238 17 239 flyers 238 folded 247 folks 251 follow 282 follow 214 216 following 164 286 298 foot 202 Foote 6,9,12,16,18 295 Foote's 289 force 219 forever 171 forget 238 forgetting 224 forgot 225 forklift 196 form 12,19 9,24 173 14,17 175 176 4,11,19,25 15,19 179 180 181 182 3,14 3,14 185 14,20,25 1,7,11,47,14 10,14,18 191 192 193 9,18 9,18 198 203 203 204 7,19,25 205 208 211 15,20 225 227 229 231 235 243 3,24 252 257 258 262 264 266 269 9,19 282 283 6,22 28515 288 289 290 294 295 formed 221 forth 176 191 194 195 208 230 290 fortunately 186 foundation 186 190 195 201 204 4,21 208 251 282 285 287 289 290 293 frame 5,20 173 193 236 frangible 271 Frank 212 fresher 257 friability 290 friable 282 3,18 6,11 15,18 290 friend 209 212 283 front 165 8,17 251 full 222 289 fully 16,17 180 function 197 199 271 further 220 259 275 298 G game 220 gas 241 264 gauge 172 174 gauges 2,13,22 gears 272 GEER 165 general 196 203 219 229 238 267 269 generally 169 173 174 175 177 182 185 193 2,17 200 204 206 209 210 213 7,11 219 224 19,24 19,24 232 250 254 272 288 generate 218 238 generated 217 218 232 234 254 258 260 265 267 gentleman 197 gentlemen 184 getting 215 give 174 14,15 192 203 204 8,22 224 239 268 276 279 279 280 given 169 232 282 298 gives 241 giving 171 214 231 Gloria 164 217 GLYNN 164 go 177 182 12,19 209 213 230 236 239 240 241 245 4,17 250 3,17 254 255 258 259 266 267 272 273 276 277 going 168 169 170 198 18 199 204 205 206 207 Doby Professional Reporting Inc. 952-943-1587 Raymond A. Anderson Jr. 7/19/2018 Page 302 13,19 11,23,2114,23,24 220 221 224 2.239 17,17,22 241 246 250 22,24 6,10 255 256 272 273 274 6,11 7,17,25 287 292 3,19 3,19 297 good 168 169 173 209 5,25 5,25 213 216 9,20,22 236 277 goods 163 164 166 167 168 11,14,23 201 10,19 273 274 274 Goods 274 gotten 252 graph 202 great 219 green 174 175 21,22 grievance 212 grievances 212 ground 223 group 21,22 7,20 289 295 groups 270 gtrattles@crowell.com 164 guess 178 191 205 guessing 187 gun 182 6,19 7,22 186 187 187 286 290 11,16 294 gunpowder 10,24 224 guns 185 187 gunshot 188 Gunsmith 251 guy 189 guys 184 189 192 199 272 296 H H 165 177 17,21 224 1,6,15 226 13,14,15 4,25 231 235 237 17,18 242 250 264 296 habits 194 hair 225 231 half 187 230 halfway 233 261 290 hammers 205 hand 223 242 298 handful 22,25 handle 223 hands 189 222 handwriting 169 217 277 handwritten 216 happened 205 257 happens 205 hard 202 222 14,21,22 223 227 228 242 Hartford 163 168 298 Haskell 282 291 292 hat 192 hazy 174 He'll 284 head 15,16 226 7,10,12,13 7,10,12,13 255 262 hear 2,15 heard 199 14,19,20 200 10,16,20,21 231 272 294 height 241 help 217 4,22 259 267 291 292 293 helped 208 helps 244 hey 192 199 high 202 230 243 16,24 higher 293 Highway 164 hit 196 HKM 164 hold 20,21 244 286 holding 277 holes 242 hopefully 275 horse 225 231 hospital 278 hour 213 hourly 211 housekeeping 194 Houston 164 hundreds 203 hung 9,13,14 HUSCH 164 hydraulically 221 hygiene 292 hypothetical 171 idea 184 201 202 203 271 identical 269 identification 218 231 232 234 238 250 253 257 260 262 265 266 273 273 11,16,19 281 identified 240 identify 220 221 239 240 6,21 267 identifying 253 ignition 259 illnesses 214 IMO 165 IMOWU 11,12 212 important 243 house 211 inch 221 2,11 230 inches 196 202 244 include 185 211 263 11,13 included 195 including 171 increase 256 increases 212 259 indicate 233 indicates 235 265 indication 220 individual 182 183 10,12 192 198 198 203 213 individual's 202 individually 183 24,25 individuals 1,24 209 5,11 211 213 214 215 indoctrination 194 industrial 291 292 Industries 165 inform 260 information 166 208 218 219 5,17,19 ingredient 226 4,6,9,12 ingredients 224 225 283 inherent 259 initial 293 initials 277 293 asbestos 163 168 inside 23,24 instill 194 instructional 250 intact 229 230 249 252 integral 242 269 integrated 19,21 integrity 249 intend 215 intended 271 intent 252 interact 191 interest 219 interested 298 interesting 222 internal 188 5,8,10 199 199 International 14,17 255 5,8,24 interpreting 232 introduce 238 introduced 220 243 259 267 269 270 Introduces 166 257 257 introducing 238 239 267 introduction 218 259 involved 3,6,9 199 294 295 Irvine 189 issue 16,16 issues 214 itemize 219 items 212 J J 289 J.A 167 281 J.C 183 JACKSON 164 jackson.otto@huschbl 164 James 291 292 January 220 232 234 257 258 9,24 263 265 282 JARDINE 165 job 210 244 John 18,19 186 209 291 Johns 8,17,19,24 199 204 journals 201 Jr 163 166 167 270 281 298 judge 290 judicial 168 July 163 168 298 13,25 jury 268 K K 164 O 200 Karst 164 19,19 169 1,3,19,22 14,22 171 2,11,16,25 9,24 8,12,15,23 175 6,11,20 176 177 13,23 5,11,14 17,22 14,25 180 181 182 182 7,17 185 1,17,22 1,8,19 188 4,11,18 12,16,20 1,14 193 7,15,21 195 198 201 19,22 8,21 3,12 3,12 7,23 208 12,17,23 209 212 213 19,23 20,23 216 217 217 219 223 223 225 227 231 235 14,17 243 248 3,24 251 252 257 258 262 264 266 269 272 275 8,18,20 9,24 277 278 279 279 2,13 281 13,14,18 282 19 7,16 7,16 11,25 10,22 287 288 288 289 290 291 5,17 2,4,7,11 293 294 295 17 296 297 keep 203 204 213 241 Keli 168 3,17 Kenny 184 186 kept 4,20,23,24,25 204 205 243 key 259 kind 176 187 217 218 19,22 233 233 1,10 236 239 240 252 261 267 287 288 kinds 199 203 14,16 Kleanbore 221 knew 190 196 289 291 know 171 176 178 179 4,25 184 184 8,10,16,23,24 8,10,16,23,24 185 8,21 187 187 8,8,15,17,18 190 7,10 196 197 5,7,18,22 5,7,18,22 200 201 6,8,14,14 201 1,4,5 203 17,18 205 206 6,7,9,19,22 207 207 17,23 210 212 24,25 215 12,15,16 5,23 218 220 225 227 230 239 248 250 251 11,12,13 269 10,21 8,17 8,17 288 6,18,6,181,19,2396,,18,219,323 2,4,25 3,23 292 293 15,19,24,25 294 knowledge 170 182 183 187 194 194 197 205 206 216 236 271 298 knowledgeable 274 known 221 242 Kordas 167 270 5,20,21 17,18 287 293 3,5,6 295 Kordas's 5,25 Kote 200 L L.J 289 lab 2,11,19 6,19 3,12,23,25 3,12,23,25 204 206 208 7,11 292 labelled 241 Laboratory 282 291 lack 228 Lake 165 large 187 19,21 243 lasted 278 late 227 290 Law 163 165 298 Lawrence 289 11 layman's 268 lead 243 left 192 203 205 211 223 240 247 253 254 293 hand 220 239 241 10,17 261 266 270 281 legal 168 legible 277 legs 253 length 169 230 Leone 165 168 let's 173 175 193 204 209 217 239 240 245 251 253 287 letter 167 280 281 4,14,20,25 4,14,20,25 282 10,11 283 284 284 290 291 5,12 letterhead 281 lettering 202 library 201 20,23,25 203 19,21,23 9,10 204 12,12,18 205 209 life 252 Doby Professional Reporting Inc. 952-943-1587 Raymond A. Anderson Jr. Page 303 light 271 lighter 175 limited 199 226 278 279 LINDQUIST 165 line 224 240 251 269 270 272 liner 240 lines 260 269 list 7,8,9,19,20 7,8,9,19,20 176 5,9,150,9,10 204 218 218 219 220 231 232 233 5,17 235 239 254 256 262 1,2,8,17 13,18 listed 170 256 listing 263 lists 217 10,13,18 21,24 219 232 260 263 literally 203 literature 204 little 173 174 180 202 17,18 223 230 231 9,14,20,21 247 250 255 256 272 284 289 LITTLETON 165 live 184 lived 200 290 load 19,23 173 174 228 7,10 233 235 236 237 16,17,19 243 247 250 22,24 255 10,25 259 261 268 5,7,16 272 272 295 loaded 7,9,17,18 180 181 loaders 250 loading 190 256 loads 166 170 172 172 1,12,11,612,16 175 10,11,13,17,18,19 181 220 22,22,22,24 228 233 13,20 234 235 4,8,13,2,25 4,8,13,22,25 236 237 7,13 243 245 248 250 254 14,1184,18 255 256 5,24 258 261 267 22,23,24 269 270 279 located 271 284 location 188 locked 259 LOGAN 165 Logically 209 logo 176 long 199 215 long 197 longer 192 10,15 Lonoke 207 15,25 210 look 174 201 202 208 217 235 239 241 243 10,17 255 258 264 270 277 282 283 looked 222 12 232 239 254 255 256 263 looking 198 203 217 229 234 247 260 268 278 283 292 looks 207 221 259 282 287 loose 202 lost 208 lot 189 198 217 222 224 231 239 288 Lots 189 Louis 164 low 12,17,18 lower 246 281 lucky 184 related 214 luster 222 M.W 167 270 281 machine 3,10 195 16,17 210 222 222 223 251 256 machines 4,9,10 7,8,12 magazines 15,18 3,5,7,12,14 mailings 186 18,19,24 main 225 269 major 176 243 majority 278 making 277 management 210 212 manager 197 289 manager's 205 managers 210 Manhattan 200 manufacture 191 271 manufactured 172 269 24,25 Manville 198 8,17,19,24 199 204 March 192 193 mark 239 246 250 273 274 281 marked 177 218 231 2,20 233 234 7,10 250 18,214 8,24 253 18 9,13 7,10 21,25 13,17 266 273 18,23 11,15 276 280 281 market 249 marketing 4,7,9 MARTINEZ 164 Marty 17,18,19 Massachusetts 15,18 material 225 20,20 285 materials 198 10,18 288 matter 168 214 215 matters 215 298 McGilton 168 3,17 McMillan 209 20,22 210 MD 292 MEAGHER 165 mean 194 208 215 229 237 252 277 279 291 meaning 174 186 205 means 197 meant 169 MEC 250 251 252 medical 12,16 292 293 medicine 291 mediums 10,1110,11 meet 275 meeting 198 215 meetings 21,24 member 210 members 20,23 membership 211 memory 174 3,13 259 261 15 293 mention 195 198 mentioned 173 177 177 178 179 187 194 195 198 207 229 245 278 283 292 294 met 291 metal 181 221 245 8,14 246 286 287 288 mid 193 middle 239 mile 200 mileage 215 millions 222 mine 165 209 212 Mines 199 Minneapolis 4,13 Minnesota 1,13 168 182 13,18,24 minute 186 217 292 minutes 213 251 253 277 Misstates 257 276 8,20 278 279 288 291 mixed 224 284 mixture 283 10,1110,11 286 MN 164 4,13,17 MO 164 modified 270 mold 225 Mold 10,11 moment 225 227 244 month 203 Morgan 291 12,14 292 MORING 164 moming 168 3,4,8 169 20,22 275 276 277 Mortl 164 168 17,21 12,19 9,24 8,14,21 4,23 3,9,14,17 3,10,12 176 177 11,19,25 10,15 178 12,19 180 181 17,20 183 183 184 185 14,20,25 6,17 188 1,7,14 277 10,14,18,23 192 | 2,25 194 195 | 198 201 203 | 204 7,19,25 205 NJ 165 nomenclature 220 lethal 271 287 power 243 4,21 208 10,21 shot 243 209 211 13,22 normal 258 265 215 18,20,23 267 286 217 218 219 16,21 225 227 Notary 3,17 3,17 notations 277 6,19 232 233 notebook 213 234 235 238 notebooks 2,11,19 16,18,21 5,20 248 249 5,25 250 16,23 252 253 253 257 258 6,19 203 13,23,25 204 206 208 noted 251 notes 216 260 17,24 264 10,16 266 267 269 19,20 11,25 18,22 275 276 276 277 278 notice 166 2,5,6 168 273 13,17,22 2,5,7,10,15,20,21 number 168 203 220 232 234 243 254 257 9,19 1,10 261 3,23 266 11,16 12,15 283 15 284 6,8,22 5,15 5,15 287 288 289 3,23 290 291 291 1,3,5,8 293 16,25 14,19,22,24 14,19,22,24 296 296 Mountain 273 mouth 180 294 move 204 242 295 moved 209 262 Moving 227 Murtha 163 168 298 mute 169 MWK 293 4,16 numbers 217 232 234 238 253 numerous 211 NW 164 {e) O'BRIEN 165 oath 169 298 obit 197 object 251 281 objection 12,19 171 171 8,14,28,114,21 4,23 3,9,14,17 3,12 176 4,11 19,25 15,19 12,19 180 181 17,20 3,14 3,14 184 185 186 N 166 name 168 174 175 175 188 200 20,21 202 203 209 210 251 273 278 289 named 197 298 names 184 287 20,25 6,17 188 1,7,14 191 10,14,18,23 192 9,18 195 198 201 16,20 16,20 204 19,25 205 206 206 4,10,21 209 211 215 national 211 near 215 219 15,2015,20 225 227 231 235 need 173 292 295 296 negatively 194 neglected 205 neither 236 Nemours 163 7,22 167 273 4,14 never 184 186 198 243 248 3,24 3,24 251 16 252 257 258 262 264 266 269 278 9,19 1,10 12,115 2,15 6,15 6,22 5,15 287 288 289 199 212 244 244 249 271 2,13 293 294 295 271 278 279 291 new 166 197 203 203 218 219 objections 167 274 14,20,21 275 294 observations 192 11,14,15 228 6,12,17,20 239 258 259 261 observe 223 obtain 208 obtained 202 262 267 270 270 obviously 180 198 230 251 news 166 257 6,13,17 257 258 occasion 193 occurrence 257 plated 255 256 offered 234 264 266 night 256 7,11,24 offering 236 267 Doby Professional Reporting Inc. 952-943-1587 Raymond A. Anderson Jr. Page 304 offerings 254 office 192 205 Offices 163 165 298 OISTE 164 okay 173 180 182 188 191 199 213 216 217 227 234 236 8,118,11 241 246 247 255 17,20 270 277 277 278 279 281 18,24 284 7,10 7,10 290 7,20 292 295 297 old 196 18,19,20 197 203 289 older 289 Olin 164 once 173 200 252 one's 241 piece 259 262 269 ones 196 203 243 279 open 223 229 249 267 opened 211 opens 247 operation 195 207 operators 210 opinion 187 193 212 291 opposed 271 16,18 opposite 187 285 ordinary 238 organization 190 orient 221 original 225 296 OTTO 164 outcome 298 outer 246 outlet 183 outside 170 202 205 207 208 powder 225 226 229 11,16 20,24 242 243 249 250 262 overall 284 Overbroad 8,21 173 174 4,11,19,25 178 179 181 188 190 193 198 278 9,19 285 Overly 219 248 249 ownership 14,17 P P 164 239 241 P.A 164 p.m 253 14 10,15 297 package 8,25 packaged 177 179 180 181 packaging 172 173 16,20 2,16 175 11,17,20 177 packed 177 264 page 166 167 219 220 221 232 234 235 244 10,22 16,16,19 | 255 258 259 | 259 3,4,7 263 264 266 267 270 271 278 291 11,12,20 293 295 pages 8,12 268 pamphlet 204 paper 169 24 202 8,14,17 19,21 235 4,6,11,14,17 236 245 246 photo 261 photograph 244 photography 243 phrase 230 physical 207 physically 201 202 picked 296 picking 296 picture 207 237 244 pictures 244 piece 169 268 285 287 paraffin 224 282 paragraph 258 259 Park 165 272 16,19,23 272 part 223 224 227 227 19,2109,20 11,12 243 244 246 3,10 249 14,2214,22 252 9,19,19 252 261 263 9,12 271 272 277 279 285 pieces 229 230 246 piston 226 234 235 6,15,20 239 241 8,118,11 12,20 11,14 2,8,18,22 2,11 245 247 250 264 278 7,11,13,23 3,16 1,4,9,13 pistons 177 178 243 279 partial 290 partially 230 particles 231 particular 170 218 5,14 229 247 252 255 256 parties 11,11 parts 176 177 188 246 250 263 place 196 244 247 249 252 273 287 places 256 Plaintiff 9,20 Plaintiff's 166 167 168 16,21 274 279 281 Plaintiffs 163 164 parts 177 passed 213 214 pat@elliottlaw.net 165 patent 11,13,16 PATRICK 165 Paul 164 PE 240 241 pen 239 246 253 277 Penney 183 Pennsylvania 164 people 182 184 189 190 12,16,23 2,9,13 192 194 194 198 199 205 210 211 211 212 251 294 percent 229 22,22 282 23,23,24 22,23 284 286 plant 170 171 182 188 9,24 189 2,21 192 192 23,24 195 197 1,25 199 10,16 7,10,17 208 6,8,9 269 271 272 plant's 207 plastic 166 177 178 181 182 14,15,17,20 14,15,17,20 226 15,25 2,19 229 232 233 233 234 235 11,14 6,10,15 236 237 6,12 6,12 239 240 7,18,22 5,11,16,22 244 22,25 247 18,23 248 255 259 percentage 193 282 percentages 283 perfect 240 264 period 7,17 174 193 287 296 periphery 284 person 192 199 212 274 293 15,19 1,4,9,13 264 9,119,11 278 296 play 178 251 playing 251 Plaza 164 please 232 234 245 251 253 298 263 273 290 personal 163 168 248 17,18 personally 179 personnel 188 PETER 164 165 Peters 5,20 175 175 18,19,20 267 phased 227 265 12,19 Philip 20,2210,21 phone 168 215 251 296 plindquist@jlolaw.com 165 point 165 175 221 221 224 227 228 236 15 239 241 244 14,25 279 280 pointing 241 283 points 5,7,18 250 policies 194 polyethylene 224 227 7,25 241 241 264 Pont 163 7,22 167 168 188 17,21 14,23 11,19,23 191 3,8,9,18,21,25 14,20 7,16,21 195 201 202 8,118,11 10,18 217 273 274 274 281 282 291 292 293 11,15 Pont's 194 274 popular 11,13,16,19 11,13,16,19 172 187 portion 240 position 229 13,19 285 positive 241 258 possession 202 post 264 265 potential 260 267 270 potentially 215 pounds 179 222 POW 242 powder 177 9,12,18 180 224 229 230 241 247 262 280 286 powders 288 power 177 178 189 226 234 235 237 6,15,20 239 241 8,11 12,19 1,11 244 2,8,18,22 2,11 245 247 250 264 6,10,13,23 6,10,13,23 279 3,7,16 1,4,9,13 PP 242 practice 273 precursor 281 282 predecessors 269 premium 15,18 preparing 215 present 192 president 19,19,21,22 19,19,21,22 2,2,3 press 238 18,20 pressure 221 222 11,17 pretty 169 273 prevent 296 prevents 241 247 previous 277 price 7,8,9,19 188 188 204 217 218 2,8,10,13,18,21,24 2,8,10,13,18,21,24 2,8,10,13,18,21,24 2,10 220 231 232 3,7,17 233 234 234 235 239 254 256 260 262 1,2,8,9,17 prices 188 219 primarily 270 283 287 prime 178 5,11,14 primer 177 20,20 221 226 230 24,25 240 247 262 270 271 11,18,20 284 284 2,11 286 priming 221 271 Pringle 164 print 186 printed 20,22,23,24 20,22,23,24 printing 175 prior 171 203 268 privilege 215 Pro 185 probably 184 187 191 193 199 8,12 205 207 242 251 Procedure 163 proceeding 276 277 277 process 191 206 210 224 11,15 249 250 251 1,3,10,16 263 296 processes 191 produced 170 234 251 271 274 274 product 170 2,17 171 177 218 219 238 260 288 production 195 227 232 256 269 272 281 products 183 216 219 234 238 257 267 270 270 22,24 288 professionals 15,16 program 223 271 progressive 224 project 4,5,6,15,20 288 289 projectile 270 3,12 271 272 12,24 282 285 2,2,3 6,7,18 288 290 290 12,13,15 projectiles 271 projects 207 promise 246 Properties 163 164 166 168 201 11,19 273 274 Properties 167 274 protected 243 public 182 11,16 204 3,17 publication 187 188 263 Publications 186 pull 283 Pumps 165 punch 222 purchase 170 6,20 208 227 235 256 purchases 170 purchasing 183 197 199 1,3,5 8,21,25 206 purely 271 purport 244 purpose 188 207 218 219 234 267 purposes 219 220 228 260 Pursuant 163 push 222 Doby Professional Reporting Inc. 952-943-1587 Raymond A. Anderson Jr. 7/19/2018 Page 305 put 173 180 195 9,11,12,13 196 5.205 234 239 241 242 246 257 260 262 263 289 292 294 putting 277 hkmlawgro 164 Q quantity 177 224 question 169 1,21 171 9,11 182 184 197 199 214 220 230 231 234 12,1182,18 257 279 284 292 296 questions 169 5,24 255 270 275 275 276 295 18,20 16,17 quick 253 275 quickly 254 quite 256 quote 276 R & 200 201 20,23,25 203 206 213 radio 11,16 Ram1s 63e 16y 8 ran 256 range 4,6,1 2906 ranges 6,7 raw 9,15 7,13,21 198 3,13 Ray 166 168 197 199 205 297 Raybestos 1,1,3 RAYMOND 163 298 reach 242 read 199 270 277 23,24 280 281 283 286 290 296 19,22 Reader's 187 reading 197 219 13,25 283 19,23 reads 241 really 170 175 178 182 183 184 184 185 186 187 190 193 198 207 271 290 reason 204 23,25 252 17,19 10,13 reasons 243 recall 176 178 179 180 181 182 193 195 196 199 200 205 209 212 224 227 248 255 256 258 259 265 17,22 276 279 283 287 289 294 receive 186 215 received 215 receiving 186 215 recognize 253 recollection 195 197 212 9,15 258 259 262 265 11,17 278 279 291 292 record 2,18,20 216 216 220 240 253 10,16,21 270 11,16 278 279 297 298 recordkeeping 273 records 7,14 171 171 205 3,11 206 13,14,15,18 13,14,15,18 208 208 3,6,7,8,10,11 RECROSS 166 EXAMINATI 295 red 165 239 253 REDIRECT 166 275 reduced 290 298 refer 246 291 reference 204 233 235 239 referenced 267 referred 278 referring 183 10,1160,16 222 224 225 241 243 245 270 271 refers 220 255 reflect 168 170 reflected 275 refold 248 refresh 195 259 267 refresher 256 refute 170 regard 231 241 258 278 294 regarding 208 212 regards 176 region 184 regular 180 218 232 234 254 257 260 263 regularly 193 270 related 21,22 208 285 relates 214 216 relations 193 relationship 212 relative 10,11 relatively 3,22,25 175 176 177 197 284 285 release 166 238 7,14 294 releases 257 18,18,20,20 258 reload 10,11 250 251 252 reloadability 259 reloaded 1,7,15,17 249 reloader 251 reloading 227 241 248 11,15,22 7,11 251 252 263 9,11 9,11 remain 230 remaining 19,20 230 remains 247 remember 175 185 188 189 18,1198,19 8,23 198 209 210 211 212 13,14,21 217 8,18 256 277 283 287 15,18 294 Remington 7,8,9,171,8,9,1 13,17,18,20 170 9,15 3,6,21,22 172 5,11,19 175 1,17,23 1,10,25 179 181 182 182 183 13,15,22 184 7,13,20,22 6,10 5,15 188 1,11,12,13,18,22 24,25,2254,25,25 13,19 1,8,13,21 5,25 13,14,13,114,18,820,21 ,132,140,1,8,220,121 8,16,17,24 195 9,11 15,25 199 200 4,13,19,23 201 17,23 206 207 210 215 216 1,8,9 218 8,9,21 220 11,14,18 223 230 15,22 232 10,25 4,7,9,24 4,22 7,18,21,24 236 238 6,12,18,20,22 6,12,18,20,22 239 248 16 249 250 1,22 254 254 257 258 259 260 5,14,16 13,20,25 13,20,25 6,10 6,10 264 1,5,8,12,17 1,5,8,12,17 265 266 7,12 267 269 270 271 16,19,23,25 16,19,23,25 273 21,23 283 288 12,14,21 291 11,14,21,23 Remington's 218 234 244 254 256 258 260 263 266 267 Remington 226 Remington 166 266 267 Remington 166 7,13,15 9,23 260 261 removed 248 24,24,25 252 repeat 173 repeated 241 247 248 repeatedly 7,15 replace 196 268 replaced 250 263 replacement 179 197 replacements 178 179 replacing 22,23 reporter 167 168 196 reporting 289 representative 215 represented 212 representing 2,7,17 164 2,7,11,16 20,21 request 217 resale 227 research 210 15,17 18,20 271 287 287 13,14 295 295 residue 223 230 respect 255 response 281 Retail 263 retained 167 retired 185 208 reused 249 reviewed 169 220 276 reviewing 217 232 254 lokt 16,1186,18 rifle 230 231 Riflemen 187 right 169 179 180 181 198 211 219 221 222 16,23 1,6,14 237 240 5,17 245 247 249 250 13 258 263 263 265 267 268 280 282 283 284 285 right 289 rimfire 270 3,3,5,5 18,20,22,24 18,20,22,24 280 284 riots 287 rises 248 Robert 163 164 168 Rocco 165 168 roll 210 room 168 roughly 172 283 290 round 228 rubber 9,13 225 282 Rule 163 run 209 RXP 21,23,24 268 13,16 7,12,15 270 $s S 246 289 safety 165 166 190 5,8,12,13 5,8,12,13 196 4,5,11 257 257 sale 170 182 183 185 219 234 236 245 263 265 266 7,13 sales 7,14 171 3,5,7,11,21,24 186 198 219 256 salespeople 184 sanction 256 saw 185 186 220 237 239 252 257 271 278 283 289 saying 199 285 13,21 288 says 174 220 224 225 232 233 235 244 247 258 262 263 264 271 6,21 283 286 286 287 8,13 scope 218 232 234 238 254 258 260 263 266 267 Scott 6,10,11,15,18 289 295 script 16,25 scroll 175 sealing 241 264 search 201 207 251 searches 201 Sears 183 second 163 166 167 9,24 185 219 220 241 244 245 251 258 16,21 274 291 11,12 293 secondly 249 secret 262 secretary 23,25 section 185 12,15 241 254 266 290 see 188 192 220 10,25 7,13 224 227 229 232 16,24,25 3,9,15 233 234 22,24 235 237 238 239 2,15 3,7,16 243 244 16,21,23 245 12,18,18 247 250 14,24 20,23 255 12,23 11,16,23,25 261 13,19 262 264 264 10,15,15 266 19,21 268 270 16 271 281 281 282 8,19,20,24 8,19,20,24 287 292 293 seeing 182 seen 185 207 222 262 265 277 278 sell 179 3,11 181 9,24 3,15 183 selling 23,24,25 183 5,18 265 senior 17,17 sense 286 sent 206 273 sentence 241 245 259 282 290 separate 185 190 190 269 271 separated 244 series 274 serious 217 served 212 set 231 233 238 260 265 SGPI 217 220 234 267 SGP10002628 232 SGP10002716 238 SGP10002930 253 SGP10002986 263 SGP10003010 260 SGP10003050 257 SGP10003130 265 Doby Professional Reporting Inc. 952-943-1587 Raymond A. Anderson Jr. 7/19/2018 Page 306 Shame 229 sheen 223 224 sheet 169 170 171 shur 232 233 234 7,18,21 239 4,7,9 shut 206 sheets 232 side 171 243 18,21 shell 172 177 180 244 254 180 6,7,9 220 | sign 18,24 5,11 15,17,20 2,11 197 20,22 16,20,23 5,14 signature 293 296 226 227 228 signs 195 8,17,18 229 3,8,10,18,20 230 196 19,20 7,12 233 6,8,12 similar 176 181 235 1,2,10,11 13,22 11,16,19 7,16 232 234 254 1,2,6,7,8 257 17,19 9,23 260 262 263 247 4,8,11,16,19,21 248 9,16,25 249 250 11,19,20,21 ,319,20,23 252 254 255 Similarly 237 241 single 274 sir 217 218 219 220 222 224 2,6,15,19 2,6,15,19 261 268 5,14,16 269 280 16,18,20 285 4,6,8,9 shells 172 173 178 178 1,3,5,11,14 180 17,20,24 2,15 191 220 14,17 10,11,23 236 237 3,5,21,24 245 1,15 256 10,12,15 259 263 5,7,10 272 11,13,22 273 278 279 295 296 shift 256 226 227 1,9,20 234 238 243 251 17,2147,24 255 257 2,12 262 263 10,20 4,22 272 274 sitting 206 situations 212 Sixth 165 size 174 skeet 166 234 235 235 19,22,25 7,12 254 261 267 skirt 242 slight 222 slightly 193 Slow 284 shipped 18,21 206 shirt 192 shooter 248 2,7,8 shooting 7,21 256 279 296 slowly 239 small 11,12 8,15 231 smooth 222 sold 173 176 177 shop 183 Shops 185 short 169 295 4,7,12 179 18,22,22 1,12,14,15 181 182 185 249 Shorter 197 shortly 227 266 shot 174 177 179 179 180 228 10,12 10,25 3,17 232 233 234 235 7,19,21 239 243 3,5,6 11,18,19 245 246 247 256 262 250 19,20 265 269 solid 12,19 somebody's 203 sorry 170 10,22 193 13,1143,14 236 294 sort 238 270 271 Sounds 200 216 source 204 South 165 shotgun 191 221 230 232 239 243 10,15 271 278 SP 11,12 speak 206 speaking 169 173 185 193 197 shotguns 214 shots 243 shotshell 207 251 269 273 279 283 284 4,13 294 213 215 special 218 specific 175 188 190 196 200 206 215 276 278 288 294 shotshells 166 198 214 9,16 9,16 280 show 170 179 218 223 236 241 243 244 250 specifically 179 180 182 4,18 185 196 197 10,17 7,12,13 215 230 238 256 250 276 277 showing 234 238 253 254 257 260 262 265 276 10,21,25 shows 242 277 278 279 282 288 specification 256 specifications 174 245 255 speculation 171 282 6,16 287 290 291 14 294 295 speed 16,24 286 spent 247 9,22 273 296 splits 248 spoke 185 spoken 14,17,25 sporting 163 164 13,17,21,23 167 168 185 10,14,22 201 10,18 253 253 6,11,13 266 267 273 3,5,9,19 spouses 214 square 221 2,11 St 19,23 staff 293 stages 252 stamp 281 standard 196 202 243 standards 194 stands 211 start 216 221 230 255 started 176 193 261 265 266 Starting 239 starts 241 290 state 163 164 168 168 18,24 278 298 stated 245 276 281 statement 276 298 States 256 sanctioned 256 stating 276 station 193 stationed 8,13 stay 227 244 247 18,21 249 252 stayed 176 stays 247 252 steel 221 226 step 180 240 Steps 252 stick 175 246 store 183 186 stored 184 223 273 stores 182 1,6,21 183 8,11,14,22 185 Street 163 164 3,8,13 168 298 strength 259 stress 248 stretch 253 strike 200 275 string 244 strong 259 structural 249 structure 184 structured 184 Studios 168 stuff 217 256 276 276 277 subordinates 199 substance 193 substantial 256 substantially 243 22,23 sued 214 Suggested 263 suit 192 Suite 9,18,23 165 13,17 summary 277 superintendent 193 supervise 191 supervisor 189 270 287 supervisors 293 supplied 3,13 suppliers 198 supply 198 199 sure 173 20,22 180 187 196 197 200 9,17 209 212 215 216 224 226 241 242 247 270 275 276 278 289 295 surface 231 surrounds 240 246 suspect 243 Suzanna 163 164 168 switch 272 switching 231 swore 169 swom 298 T T 164 T 225 table 242 TAENNPGNL 251 take 187 196 203 14,20 216 223 239 253 254 6,25 275 283 292 taken 163 168 talk 194 talked 8,9,9 244 255 263 279 talking 173 176 9,11,22 177 179 182 189 20,22 193 197 203 204 12,13 237 250 277 279 282 284 285 286 290 291 295 talks 280 tape 6,15 target 11,13,17,19 11,13 181 182 220 4,7,10,12,17 235 13 236 6,6,14 237 16,17,19 243 244 245 247 248 7,10 254 4,22,23 14,18 20,21 5,10,24 256 22,22 259 263 268 5,7,16 24,25 11,13 295 Targets 166 3,23 tart 173 Taska's 214 te 202 Technically 268 technician 168 213 teleconference 164 television 11,16 tell 217 220 222 229 238 240 247 251 255 260 261 263 265 266 267 272 288 telling 194 286 288 ten 192 213 277 term 228 229 268 286 territories 184 territory 184 test 222 testified 214 217 226 248 14,20 249 250 14,25 14,25 264 265 272 278 testify 298 testifying 281 testimony 8,20 277 278 8,11,20 5,11,13 287 288 291 298 testing 272 5,8,10 294 text 241 Thank 168 169 213 231 260 275 296 thereabouts 234 254 266 thicker 240 thing 21,23 197 217 221 225 6,15 270 273 286 287 288 things 186 187 191 194 198 199 204 228 263 271 275 15,17 293 think 169 175 180 184 186 187 7,24 23,23 199 207 216 217 224 228 229 238 5,13 251 256 272 5,12 282 293 11,16,17 third 259 thought 256 three 181 193 232 234 236 throw 204 223 thrown 223 tie 192 time 5,7,17,20,22 173 174 179 16,1166,16 185 191 192 18,22,24 11,18 194 199 200 13,15 215 216 216 9,19 220 220 222 227 228 229 231 236 5,11,16 238 240 245 248 250 252 253 14 21,21,23,24 258 259 264 266 267 269 272 273 10,15 287 Doby Professional Reporting Inc. 952-943-1587 Raymond A. Anderson Jr. Page 307 289 297 times 207 223 timing 259 tite 225 title 188 189 197 238 251 264 titled 10,14 238 257 261 titles 189 today 185 201 207 213 214 217 275 276 17,22 Today's 168 told 214 234 276 287 291 292 292 293 tolerances 283 tome 172 tons 221 tools 189 top 10,25 228 232 234 246 255 263 268 270 280 292 20,21 topic 197 topics 215 torn 205 19,20 totally 205 208 251 touching 298 tough 223 toxicity 270 271 toxicology 291 trades 192 training 223 trap 166 234 235 19,22 6,12 239 8,16 267 traps 166 2,22 3,19 TRATTLES 164 296 tried 288 trouble 240 truck 196 true 184 227 278 282 298 truth 215 298 trying 173 193 194 198 208 240 293 294 tunnels 291 turn 219 220 261 two 186 194 12,13 13,14,15 214 225 237 246 5,15 thirds 205 TX 164 type 178 14,19 192 206 2,20 212 221 236 14,22 14,15 247 251 252 267 283 294 295 296 typed 293 types 173 177 185 204 6,19 264 typical 204 typically 174 185 294 U huh 235 261 271 284 292 | unaware 171 5,8,9 uncomfortable 217 undergone 222 undemeath 235 understand 169 170 182 234 268 274 278 9,18 understanding 222 6,17 232 243 245 251 understood 196 unibody 21,24 269 uniform 241 259 union 165 200 210 18,23 1,1,13 211 16,20,24 16,19 212 unions 210 unit 242 United 256 unprimed 180 15,19,22 20,24 2,10 upcoming 219 update 219 upper 239 261 266 289 upset 244 USA 251 USB 166 250 use 195 226 227 241 247 2,3,5 287 296 user 271 usually 293 W W 164 W 18: 4 wad 177 178 224 2,6,6,11,13,15,15 2,6,6,11,13,15,15 227 11,13,14,15 3,4,25 231 234 235 9,11 15,16,21,25 15,16,21,25 241 241 20,22,2204,22,24 243 245 262 264 278 11,11 296 wads 6,15,18 178 17,21 1,1,17,21 4,7,10,13 227 227 229 230 231 235 237 249 1,1,2,6,6 1,2,5,9,10,15,18 1,4,8 6,8,12,19 6,8,12,19 11,13 wage 210 211 212 wages 212 wait 296 Waite 12,15 185 186 waive 296 20,21,23 waiver 215 waiving 201 walk 221 16,17 walked 255 walking 191 241 wall 196 walls 205 269 Walnut 9,10 V WANNING 164 Vague 170 173 209 223 243 249 want 180 191 213 214 239 278 279 284 243 246 250 6,15 vaguely 287 varied 174 255 273 276 280 294 295 296 varies 174 wanted 254 various 217 219 234 245 250 260 263 279 warning 17,25 179 2,18 Warren 165 vary 172 vast 249 Washington 164 wasn't 189 248 vein 257 277 velocity 230 vendors 182 204 watch 251 watched 251 verify 239 version 268 versus 168 190 192 210 vice 19,22 213 vicinity 179 video 166 168 water 282 Waterbury 168 wax 2,2,8,14 282 way 187 222 224 227 230 243 249 293 we'll 213 241 250 18,21,25 5,11 14,17,21,23 videographer 165 1,23 10,15 9,14 10,15 297 275 22,22 we're 176 177 179 182 191 193 199 204 207 214 217 240 250 254 videotaped 163 168 VIP 168 261 267 286 295 visiting 189 visitor 207 we've 176 213 224 235 236 visual 258 11 voids 222 246 249 253 262 263 volume 249 12,17 256 volume 256 von 164 wear 192 weight 174 282 went 192 21,25 202 4,14 223 227 243 258 296 weren't 249 23,24 West 165 whatever's 247 whatsoever 251 white 240 wholes 205 wide 202 wife 163 168 277 William 199 Wilmington 194 Winchester 199 window 172 windows 205 wiped 243 wit 298 witness 166 13,20 171 1,10,15,23 173 4,10,18 175 175 176 12,20 1,12,16,20 179 179 181 182 182 4,15 184 185 15,21 187 187 2,8,15 11,15,19,21,145,19,24 193 1,10,19 195 198 201 18,21 204 1,11 206 206 5,11,14,22 209 212 18,21 215 216 217 227 231 243 248 276 277 278 12,20 280 282 7,10 284 7,18 7,18 287 4,24 4,24 290 291 291 292 293 294 295 298 298 wood 224 282 283 284 10,25 word 197 204 276 280 words 180 294 work 175 192 248 worked 171 174 176 184 186 188 189 21,23 201 17,17 210 211 212 213 214 257 273 281 287 289 working 201 203 204 207 210 224 231 278 279 wouldn't 183 223 286 291 wreck 205 wrestle 172 write 203 217 239 13,14 18,20 writing 217 242 277 281 298 written 175 176 wrong 292 Xx X 166 Y Yeah 200 203 228 year 203 219 232 234 251 254 256 267 years 170 171 172 174 175 4,14 176 193 8,25 207 214 217 223 289 yellow 169 10,15 Yes's 250 yesterday 5,11,22 170 176 177 178 213 229 255 256 258 258 267 270 280 11,21 291 291 14,21 14,21 294 yesterday's 276 YouTube 166 250 251 Yup 184 262 284 Z Zapp 167 5,25 282 18,19 0 0002532 220 0002700 234 0003298 267 07701 165 1 1 169 17,23 216 217 282 1/19/71 167 281 1/2 11,12 221 222 1/2/63 166 231 1/2/64 166 233 1/2/68 14,18 257 262 1/2/70 166 265 1:18 275 1:47 297 10 166 1,18,21 10:05 168 100 164 165 286 1001 164 11 166 11,12 257 257 11:04 216 11:20 216 12 166 196 5,10 12-258 12-258 gauge 172 255 258 267 269 269 12:15 253 12:25 253 12:55 275 120 165 13 166 20,25 14 166 12,17 141 165 15 166 266 267 15,000 222 150 202 16 166 273 274 169 166 17 167 270 273 1,5,6 172 267 18 167 9,19 185 163 168 298 Doby Professional Reporting Inc. 952-943-1587 Raymond A. Anderson Jr. 7/19/2018 19 163 167 168 172 251 13,20 282 190 164 19500 164 1960s 183 227 296 296 1961 166 170 171 218 219 220 1963 4,18 4,18 233 7,13,16 1964 5,17 5,17 235 239 1967 166 1,22 254 1968 166 227 256 257 258 9,24 260 5,10,13 10,16 1,2,7 265 266 1970 18,22 266 1971 270 282 1972 166 266 267 268 1980s 7,10 176 1981 170 171 19th 298 2 2 232 234 257 258 259 263 265 270 280 281 5,115,11 290 292 20 167 179 281 11,19 284 289 292 293 gauge 166 9,16 10,12,15 some 172 20004-2595 164 2018 163 168 298 298 202 164 2022 298 216 166 218 166 227-9411 164 231 166 233 166 238 166 23nd 298 24 196 261 2409 165 250 166 253 166 2533 220 2547 220 257 166 260 166 262 166 2632 232 2643 232 265 166 266 166 2704 234 2715 234 2717 238 244 245 272 166 167 274 167 275 166 gauge 172 281 164 167 290-6504 165 295 166 2969 254 2973 253 2990 263 2993 263 3 3 251 282 17,19 30 164 15,19 268 283 30.02 163 3033 261 3049 260 3053 257 31 267 268 298 3134 266 3137 265 314 164 3200 164 33 165 244 3327 267 3345 267 36 282 284 371-1321 165 3M 163 168 4 4 255 256 40 254 410 172 4400 165 466-7192 165 480-1835 164 5 5 166 218 220 227 500 164 264 53 282 284 530-9108 165 55042 165 55101 164 55402 165 55423 165 6 6 166 231 232 60 283 600 164 60s 174 176 181 183 185 8,14 294 172 612 5,14 18-169 163 168 624-2601 164 63105 164 651 164 165 66th 165 68 192 193 197 211 227 7 7 166 221 222 233 234 239 282 7/18/18 163 70s 7,10 2,21 185 8,15 207 207 290 294 732 165 77070 164 7th 164 8 166 11,12 238 238 251 80s 193 81 172 8519 165 86 185 192 202 203 205 211 9 9 166 202 220 17,20 19,2149,24 945-1974 164 94596 164 952 164 970-9988 164 99 229 Doby Professional Reporting Inc. 952-943-1587 Page 308